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(a) Attributable to the requesting spouse. The
unpaid liability or item giving rise to the deficiency
is attributable to the requesting spouse.
(b) Knowledge, or reason to know. A requesting
spouse knew or had reason to know * * * that the
reported liability would be unpaid at the time the
return was signed. This is an extremely strong factor
weighing against relief. Nonetheless, when the factors
in favor of equitable relief are unusually strong, it
may be appropriate to grant relief under �6015(f) in
limited situations where a requesting spouse knew or
had reason to know that the liability would not be
paid, * * *
(c) Significant benefit. The requesting spouse
has significantly benefitted (beyond normal support)
from the unpaid liability * * *. See �1.6013-5(b).
(d) Lack of economic hardship. The requesting
spouse will not experience economic hardship (within
the meaning of section 4.02(1)(c) of this revenue
procedure) if relief from the liability is not granted.
(e) Noncompliance with federal income tax laws.
The requesting spouse has not made a good faith effort
to comply with federal income tax laws in the tax years
following the tax year or years to which the request
for relief relates.
(f) Requesting spouse’s legal obligation. The
requesting spouse has a legal obligation pursuant to a
divorce decree or agreement to pay the liability.
The knowledge or reason to know factor, the economic hardship
factor, and the legal obligation factor in Rev. Proc. 2000-15,
sec. 4.03(2)(b), (d), and (f), respectively, are the opposites of
the knowledge or reason to know factor, the economic hardship
factor, and the legal obligation factor in Rev. Proc. 2000-15,
sec. 4.03(1)(d), (b), and (e), respectively. The attribution
factor in Rev. Proc. 2000-15, sec. 4.03(2)(a) is substantially
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Last modified: May 25, 2011