<p style="text-align: justify;">The Fourth Circuit has joined the Third and Seventh Circuits in finding that Treasury Regulation Section 1.6015(b), which imposes a two-year limitations period upon taxpayers to request equitable relief under the innocent spouse provisions of the Internal Revenue Code, is a valid regulation.  Internal Revenue Code Section 6015(f) is ambiguous as to the applicable statute of limitations, and therefore the Treasury Regulation is a reasonable interpretation of the statute.</p>
