Charles R. and Dru L. Haggart - Page 14

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               We find that Mrs. Haggart had reason to know of the                    
          understatements of tax.  As a result of our conclusion, we need             
          not determine whether Mrs. Haggart satisfies the other                      
          requirements, and hold that Mrs. Haggart is not eligible for                
          relief from joint and several liability under section 6015(b).              
          B.  Section 6015(f) Relief                                                  
               Section 6015(f) provides:                                              
                    SEC. 6015(f) Equitable Relief.–-Under procedures                  
               prescribed by the Secretary, if--                                      
                         (1) taking into account all the facts and                    
                    circumstances, it is inequitable to hold the individual           
                    liable for any unpaid tax or any deficiency (or any               
                    portion of either); and                                           
                         (2) relief is not available to such individual               
                    under subsection (b) or (c),                                      
               the Secretary may relieve such individual of such liability.           
               To prevail, Mrs. Haggart must show that respondent’s denial            
          of equitable relief under section 6015(f) was an abuse of                   
          discretion.  Jonson v. Commissioner, 118 T.C. 106, 125 (2002);              
          Cheshire v. Commissioner, supra at 198; Butler v. Commissioner,             
          114 T.C. 276, 292 (2000).  As directed by section 6015(f),                  
          respondent prescribed procedures to use in determining whether              
          the requesting spouse qualifies for relief under section 6015(f).           
          Those procedures are found in Rev. Proc. 2000-15, 2000-1 C.B.               
          447.11  The revenue procedure includes partial lists of positive            
          and negative factors to be considered, including whether the                

          11  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.                                     

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