Susan L. Castle - Page 8




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          Revenue Procedure 2000-15 lists seven conditions (threshold                 
          conditions) which must be satisfied before the IRS will consider            
          a request for relief under section 6015(f).  In the instant case,           
          respondent concedes that those conditions are satisfied.  Where,            
          as here, the requesting spouse satisfies the threshold condi-               
          tions, section 4.01 of Revenue Procedure 2000-15 provides that a            
          requesting spouse may be relieved under section 6015(f) of all or           
          part of the liability in question if, taking into account all the           
          facts and circumstances, the IRS determines that it would be                
          inequitable to hold the requesting spouse liable for such liabil-           
          ity.                                                                        
               Where, as here, the requesting spouse satisfies the thresh-            
          old conditions, section 4.02(1) of Revenue Procedure 2000-15 sets           
          forth the circumstances under which the IRS ordinarily will grant           
          relief to that spouse under section 6015(f) in a case like the              
          instant case where a liability is reported in a joint return but            
          not paid.  As pertinent here, those circumstances, which section            
          4.02 of Revenue Procedure 2000-15 and we refer to as elements,              
          are:                                                                        
                    (a) At the time relief is requested, the request-                 
               ing spouse is no longer married to * * * the                           
               nonrequesting spouse * * *;                                            
                    (b) At the time the return was signed, the re-                    
               questing spouse had no knowledge or reason to know that                
               the tax would not be paid.  The requesting spouse must                 
               establish that it was reasonable for the requesting                    
               spouse to believe that the nonrequesting spouse would                  
               pay the reported liability. * * *; and                                 





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