Lisa Marie Pierce - Page 12

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          section 6015(f).  Section 4.01 of Rev. Proc. 2000-15, 2000-1 C.B.           
          at 448, lists threshold conditions which must be satisfied before           
          the Commissioner will consider a request for relief under section           
          6015(f).  Respondent agrees that in this case those threshold               
          conditions are satisfied.                                                   
               Section 4.03 of Rev. Proc. 2000-15, 2000-1 C.B. at 448-449,            
          lists factors that the Commissioner will consider in deciding               
          whether to grant equitable relief under section 6015(f).  Section           
          4.03(1) of Rev. Proc. 2000-15, 2000-1 C.B. at 448-449, lists the            
          following factors that the Commissioner will consider as weighing           
          in favor of granting relief for an unpaid liability:  (1) The               
          requesting spouse is separated or divorced from the nonrequesting           
          spouse; (2) the requesting spouse would suffer economic hardship            
          if relief is denied; (3) the requesting spouse was abused by the            
          nonrequesting spouse; (4) the requesting spouse did not know or             
          have reason to know that the reported liability would be unpaid             
          at the time the return was signed; (5) the nonrequesting spouse             
          has a legal obligation pursuant to a divorce decree or agreement            
          to pay the unpaid liability; and (6) the unpaid liability is                
          attributable to the nonrequesting spouse.                                   
               Section 4.03(2) of Rev. Proc. 2000-15, 2000-1 C.B. at 449,             
          lists the following factors that the Secretary will consider as             
          weighing against granting relief for an unpaid liability:  (1)              
          The unpaid liability is attributable to the requesting spouse;              






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