Sandrus L. Collier - Page 30

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          present in the instant case.                                                
               The parties do not dispute that the marital status positive            
          factor, the economic hardship positive factor, and the knowledge            
          or reason to know positive factor set forth in section                      
          4.03(1)(a), (b), and (d), respectively, of Revenue Procedure                

                         (b) Economic hardship.  The requesting spouse                
               would suffer economic hardship (within the meaning of                  
               section 4.02(1)(c) of this revenue procedure) if relief                
               from liability is not granted.                                         
                         (c) Abuse.  The requesting spouse was abused                 
               by the nonrequesting spouse, but such abuse did not                    
               amount to duress.                                                      
                         (d) No knowledge or reason to know.  In the                  
               case of a liability that was properly reported but not                 
               paid, the requesting spouse did not know and had no                    
               reason to know that the liability would not be paid.                   
               * * *                                                                  
                         (e) Nonrequesting spouse’s legal obligation.                 
               The nonrequesting spouse has a legal obligation pursu-                 
               ant to a divorce decree or agreement to pay the out-                   
               standing liability.  This will not be a factor weighing                
               in favor of relief if the requesting spouse knew or had                
               reason to know, at the time the divorce decree or                      
               agreement was entered into, that the nonrequesting                     
               spouse would not pay the liability.                                    
                         (f) Attributable to nonrequesting spouse.                    
               The liability for which relief is sought is solely                     
               attributable to the nonrequesting spouse.                              
          (We shall hereinafter refer to the positive factors set forth in            
          sec. 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 knowl-             
          edge or reason to know positive factor, the legal obligation                
          positive factor, and the attribution positive factor, respec-               

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