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(f) Attributable to nonrequesting spouse. The
liability for which relief is sought is solely attrib-
utable to the nonrequesting spouse.
(We shall hereinafter refer to the positive factors set forth in
section 4.03(1)(a), (b), (c), (d), (e), and (f) of Revenue
Procedure 2000-15 as the marital status positive factor, the
economic hardship positive factor, the abuse positive factor, the
knowledge or reason to know positive factor, the legal obligation
positive factor, and the attribution positive factor, respec-
tively.)
With respect to the marital status positive factor set forth
in section 4.03(1)(a) of Revenue Procedure 2000-15, petitioner
concedes that the marital status positive factor is not present
in this case.
With respect to the economic hardship positive factor set
forth in section 4.03(1)(b) of Revenue Procedure 2000-15,24
24In determining whether a requesting spouse will suffer
economic hardship, sec. 4.02(1)(c) of Revenue Procedure 2000-15,
to which sec. 4.03(1)(b) of that revenue procedure refers,
requires reliance on rules similar to those provided in sec.
301.6343-1(b)(4), Proced. & Admin. Regs. Sec. 301.6343-
1(b)(4)(i), Proced. & Admin. Regs., generally provides that an
individual suffers an economic hardship if the individual is
unable to pay his or her reasonable basic living expenses. Sec.
301.6343-1(b)(4), Proced. & Admin. Regs., provides in pertinent
part:
(ii) Information from taxpayer. In determining a
reasonable amount for basic living expenses the direc-
tor will consider any information provided by the
taxpayer including–-
(continued...)
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