- 13 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011