Treasury Regulations · 26 CFR
§ 1.6015-4. Equitable relief.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 6015
Cite as 26 CFR § 1.6015-4
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- July 18, 2002 by T.D. 9003
- Issued under
- 26 U.S.C. § 6015
- Length
- 190 words · about 1 min to read
- Cross-references
- cites 0 Code sections and 2 regulations; cited by 6
¶(a) A requesting spouse who files a joint return for which a liability remains unpaid and who does not qualify for full relief under § 1.6015-2 or 1.6015-3 may request equitable relief under this section. The Internal Revenue Service has the discretion to grant equitable relief from joint and several liability to a requesting spouse when, considering all of the facts and circumstances, it would be inequitable to hold the requesting spouse jointly and severally liable.
¶(b) This section may not be used to circumvent the limitation of § 1.6015-3(c)(1) (i.e., no refunds under § 1.6015-3). Therefore, relief is not available under this section to obtain a refund of liabilities already paid, for which the requesting spouse would otherwise qualify for relief under § 1.6015-3.
¶(c) For guidance concerning the criteria to be used in determining whether it is inequitable to hold a requesting spouse jointly and severally liable under this section, see Rev. Proc. 2000-15 (2000-1 C.B. 447), or other guidance published by the Treasury and IRS (see § 601.601(d)(2) of this chapter).
[T.D. 9003, 67 FR 47285, July 18, 2002]
Cross-references
Computed from the citations in the text of 26 CFR.
Regulations it cites
- § 1.6015-2 Relief from liability applicable to all qualifying joint filers.
- § 1.6015-3 Allocation of deficiency for individuals who are no longer married, are legally separated, or are not members of the same household.
Cited by 6 other regulations
- § 1.6015-0 Table of contents.
- § 1.6015-1 Relief from joint and several liability on a joint return.
- § 1.6015-5 Time and manner for requesting relief.
- § 1.6015-6 Nonrequesting spouse's notice and opportunity to participate in administrative proceedings.
- § 1.6015-7 Tax Court review.
- § 1.6015-9 Effective date.
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 9003 (67 FR 47285)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Tax returns or statements
Nearby sections
- § 1.6015-0 Table of contents.
- § 1.6015-1 Relief from joint and several liability on a joint return.
- § 1.6015-2 Relief from liability applicable to all qualifying joint filers.
- § 1.6015-3 Allocation of deficiency for individuals who are no longer married, are legally separated, or are not members of the same household.
- § 1.6015-4 Equitable relief.
- § 1.6015-5 Time and manner for requesting relief.
- § 1.6015-6 Nonrequesting spouse's notice and opportunity to participate in administrative proceedings.
- § 1.6015-7 Tax Court review.
- § 1.6015-8 Applicable liabilities.