§910

910 (West 2004); McIntyre v. United States, supra; Babb v. Schmidt, 496 F.2d 957 (9th Cir. 1974); Weinberg v. Weinberg, 432 P.2d 709, 713-714 (Cal. 1967); Grolemund v. Cafferata, 111 P.2d 641 (Cal. 1941). The policies behind the law can be debated, but a decision not to disrupt this rule for tax liabilities is sound. A marital community can in

910 (West 2004). - 22 - it does not, we do not need to address whetherMs. Minihan could have pursued a wrongful levy action under section 7426.) The Supreme,Court in EC Term of·Years Trust, 550 U.S. at 433, 435, followed the axiom that "'a precisely drawn, detailed statute pre-empts more general remedies'" to hold that a refund claim under 28

ved and adjudicated is the condition of subsequent singleness of the partiesiand not the valid prior existence of marital relations between them." * * * In re Holmes' Estate, 52 N.E.2d 424, 429 (:N.Y. Ct. App. 1943), (quoting 2 Freeman on Judgments,.sec. 910). The rules we have discussed were also summarized by the Supreme Court of Vermont: A valid divorce decree is conclusive against the world as to the status of the parties as unmarried persons from the time of the decree. The divorce decree d

ved and adjudicated is the condition of subsequent singleness of the partiesiand not the valid prior existence of marital relations between them." * * * In re Holmes' Estate, 52 N.E.2d 424, 429 (:N.Y. Ct. App. 1943), (quoting 2 Freeman on Judgments,.sec. 910). The rules we have discussed were also summarized by the Supreme Court of Vermont: A valid divorce decree is conclusive against the world as to the status of the parties as unmarried persons from the time of the decree. The divorce decree d

910 (West 2004). Cf. Ordlock v. Commissioner, 126 T.C. at 56 (concluding that the “notwithstanding” provision of section 6015(g)(1) does not take precedence over State community property laws which are necessary to define ownership in payments). Congress enacted section 6015 as a means of expanding relief to innocent spouses. See H.R. Conf. Re

910 (a) (West 2004) ; In Re Soderling, 998 F.2d 730, 733 (9th Cir. 1993) . Because Churchill was married at the time of the CDP hearing, the Appeals officer was right to consider Schwarz's assets and income - 10 - in evaluating his offer.s See sec. 301.7122-1(c) (2) (ii) (B), Proced. & Admin. Regs. Churchill also argues that the Appeals offic

910 (West 2004) ; Ordlock v . Commissioner , 533 F .3d 1136, 1138 (9th Cir . 2008), affg . 126 T .C . 47 (2006) . Under California law "all property, real or personal, wherever situated, acquired by a married person during the marriage while domiciled in * * * [California] is community property ." Cal . Fam. Code sec . 760 (West 2004) ; see al

910 (West 2004); McIntyre v. United States, supra; Babb v. Schmidt, 496 F.2d 957 (9th Cir. 1974); Weinberg v. Weinberg, 432 P.2d 709, 713-714 (Cal. 1967); Grolemund v. Cafferata, 111 P.2d 641 (Cal. 1941).6 The policies behind the law can be debated, but a decision not to disrupt this rule for tax liabilities is sound. A marital community can i