Sarah Joan Barber - Page 14

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          July 22, 1998.  The Court, therefore, considers petitioner's                
          entitlement to relief under Rev. Proc. 2000-15, sec. 4.02, supra.           
               If a requesting spouse satisfies all of the applicable                 
          threshold conditions, Rev. Proc. 2000-15, sec. 4.01, provides               
          that such spouse may be entitled to relief under section 6015(f)            
          if, taking into account all of the facts and circumstances, the             
          IRS determines that it would be inequitable to hold the                     
          requesting spouse liable for such liability.  Where a liability             
          reported on a joint return is unpaid, Rev. Proc. 2000-14, sec.              
          4.02, provides the circumstances under which equitable relief               
          under section 6015(f) will ordinarily be granted.  Where, as                
          here, a taxpayer does not qualify for relief under section 4.02,            
          the IRS may still grant relief under section 4.03.  Rev. Proc.              
          2000-15, sec. 4.03, supra, provides a partial list of positive              
          and negative factors that will be taken into account in                     
          determining whether full or partial relief will be granted under            
          section 6015(f).  No single factor is to be determinative in any            
          particular case; all factors are to be considered and weighed               
          appropriately, and the list of factors is not intended to be                
          exhaustive.  Collier v. Commissioner, T.C. Memo. 2002-144; Rev.             
          Proc. 2000-15, sec. 4.03.                                                   
               Rev. Proc. 2000-15, sec. 4.03(a), supra, sets forth positive           
          factors that weigh in favor of relief.  As pertinent here, that             
          section provides:                                                           





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