Judge Mark V. (“Vittorio Emanuele”) Holmes shoots the Section 6015 giant slalom without a single tangle in the partitive genitive gates in Jodell Sample, T. C. Memo. 2025-118, filed 11/17/25. Jodell still lived with hubby dentist Joe although legally separated (from which separation she walked away with “one of their shared cars, their main residence in Minnesota, a second home in Montana, and [hubby dentist Joe]’s entire section 401(k) account,” 2025 T. C. Memo. 2025-118, at p. 3).

Nonetheless, Jodell, a high school grad who ran hubby Joe’s dentist’s office while claiming to know nothing of their tax posture even after an IRS agent visited, ducks joint-and-several for three (count ’em, three) years at issue, while going under for the remaining four (count ’em, four), the dividing line between knowing and not knowing being the open years after IRS agent’s visit.

The economic dividing line is the usual sumptuary scan.

“Sample doesn’t live a life of luxury, traversing the world on expensive vacations, sporting couture in sophisticated sports cars. See Rev. Proc. 2013-34, § 4.03(2)(e). Because we do not see the typical hallmarks of significant benefit, we will not find that Sample had more than normal support from her unpaid tax liability.” T. C. Memo. 2025-118, at p. 19. (Citations omitted). If you’re going for innocent spousery, the old rule KISS (Keep it Simple, Stupid) controls.

And Jodell didn’t put in additional information, despite chances to do so.

I note her trusty attorney has appeared in this my blog before, and he definitely knows his way around. If he’s not holding cards, he doesn’t play. And he did play a stormer in the factors game, getting 12 (count ’em, 12) favorables against only three (count ’em, three) negatives, with the remaining twenty (count ’em, twenty) being neutral. See Judge Holmes’ table, T. C. Memo. 2025-118, at p. 20.

A good review of the innocent spousery analysis.

Don’t miss David B. Fugler and Cindy D. Fugler, T. C. Sum. Op. 2025-10, filed 11/17/25. Dave’s a lawyer, but unlike the Golden Gopher alum who represented Jodell, he’ll play a busted hand with the best. He wants innocent spousery for both himself and his wife.

Ex-CSTJ Lewis (“Ya Gotta Love That Name”) Carluzzo is not amused.

“Aside from petitioners’ failure to show that any of the factors that are taken into account in deciding whether a spouse is entitled to section 6015(f) relief apply to petitioner, it would seem to offend common sense to allow both spouses section 6015 relief with respect to the same income tax liability. As we have previously noted, section 6015 relief is generally available to only one spouse for a single tax year… and in this case it is not petitioner.” T. C. Sum. Op. 2025-10, at pp. 7-8. (Citation omitted).