Sandrus L. Collier - Page 36

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          Collier contends that none of those factors is present in the               
          instant case.                                                               
               The parties agree or do not dispute that the knowledge or              

                    (2) Factors weighing against relief.  The factors                 
               weighing against relief include, but are not limited                   
               to, the following:                                                     
                         (a) Attributable to the requesting spouse.                   
               The unpaid liability * * * is attributable to the                      
               requesting spouse.                                                     
                         (b) Knowledge, or reason to know.  A request-                
               ing 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. * * *                                         
                         (c) Significant benefit.  The requesting                     
               spouse has significantly benefitted (beyond normal                     
               support) from the unpaid liability * * *.                              
                         (d) Lack of economic hardship.  The request-                 
               ing spouse will not experience economic hardship (with-                
               in 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.                 
          (We shall hereinafter refer to the negative factors set forth in            
          sec. 4.03(2)(a), (b), (c), (d), (e), and (f) of Revenue Procedure           
          2000-15 as the attribution negative factor, the knowledge or                
          reason to know negative factor, the significant benefit negative            
          factor, the economic hardship negative factor, the noncompliance            
          negative factor, and the legal obligation negative factor,                  

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