Marie-Francine T. Grow - Page 9

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          Those procedures are found in Rev. Proc. 2000-15, 2000-1 C.B.               
          447.2  The revenue procedure includes a partial list of the                 
          positive and negative factors to be considered, including whether           
          the requesting spouse is divorced, whether the requesting spouse            
          would suffer undue economic hardship, whether the requesting                
          spouse “had no reason to know of the items giving rise to the               
          deficiency”, and whether the requesting spouse significantly                
          benefited from the items giving rise to the deficiency.  See Rev.           
          Proc. 2000-15, sec. 4.03(1) and (2), 2000-1 C.B. at 448-449.  We            
          are at a loss to explain respondent’s comment that petitioner has           
          not shown undue economic hardship.  In a Statement of                       
          Disagreement as to respondent’s denial of innocent spouse relief            
          petitioner stated that she suffered from fibromyalgia and could             
          not work, she had to live at a friend’s house because she could             
          not afford her own home, her former husband is not paying alimony           
          as required by the divorce decree, and she did not make “ends               
          meet.”  This statement has not been questioned by respondent.  It           
          seems that respondent was exclusively focused on whether she knew           
          or had reason to know of the items that gave rise to the                    
          deficiency.  But, even if we assume that she did, “No single                
          factor will be determinative of whether equitable relief will or            
          will not be granted in any particular case.  Rather all factors             


          2  Rev. Proc. 2000-15, sec. 3, 2000-1 C.B. 447, 448, is                     
          applicable for any liability for tax arising on or before July              
          22, 1998, that was unpaid on that date.                                     




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