- 8 - Those procedures are found in Rev. Proc. 2000-15, 2000-1 C.B. 447.2 The revenue procedure includes a partial list of the positive and negative factors to be considered, including whether the requesting spouse is divorced, whether the requesting spouse would suffer undue economic hardship, whether the requesting spouse “had no reason to know of the items giving rise to the deficiency”, and whether the requesting spouse significantly benefited from the items giving rise to the deficiency. See Rev. Proc. 2000-15, sec. 4.03(1) and (2), 2000-1 C.B. at 448-449. We are at a loss to explain respondent’s comment that petitioner has not shown undue economic hardship. In a Statement of Disagreement as to respondent’s denial of innocent spouse relief petitioner stated that she suffered from fibromyalgia and could not work, she had to live at a friend’s house because she could not afford her own home, her former husband is not paying alimony as required by the divorce decree, and she did not make “ends meet.” This statement has not been questioned by respondent. It seems that respondent was exclusively focused on whether she knew or had reason to know of the items that gave rise to the deficiency. But, even if we assume that she did, “No single factor will be determinative of whether equitable relief will or will not be granted in any particular case. Rather all factors 2 Rev. Proc. 2000-15, sec. 3, 2000-1 C.B. 447, 448, is applicable for any liability for tax arising on or before July 22, 1998, that was unpaid on that date.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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