Marc S. Feldman - Page 9

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          required for relief.  If the threshold conditions are satisfied,            
          Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, lists                    
          circumstances where relief will generally be granted, subject to            
          two limitations.  If it is unclear whether these circumstances              
          are satisfied, the Commissioner looks to Rev. Proc. 2000-15, sec.           
          4.03, 2000-1 C.B. at 448, to determine whether the taxpayer                 
          should be granted equitable relief.                                         
               Rev. Proc. 2000-15, sec. 4.03(1), 2000-1 C.B. at 448, lists            
          the following six factors that the Commissioner will consider as            
          weighing in favor of granting relief for an unpaid liability                
          (positive factors):  (1) The requesting spouse is separated or              
          divorced from the nonrequesting spouse; (2) the requesting spouse           
          would suffer economic hardship if relief is denied; (3) the                 
          requesting spouse was abused by the nonrequesting spouse; (4) the           
          requesting spouse did not know or have reason to know that the              
          reported liability would be unpaid at the time the return was               
          signed; (5) the nonrequesting spouse has a legal obligation                 
          pursuant to a divorce decree or agreement to pay the unpaid                 
          liability; and (6) the unpaid liability is attributable to the              
          nonrequesting spouse.  Rev. Proc. 2000-15, sec. 4.03(2), 2000-1             
          C.B. at 449, lists the following six factors that the                       
          Commissioner will consider as weighing against granting relief              
          for an unpaid liability (negative factors):  (1) The unpaid                 
          liability is attributable to the requesting spouse; (2) the                 






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