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section 6015(f). Section 4.01 of Rev. Proc. 2000-15, 2000-1 C.B.
at 448, lists threshold conditions which must be satisfied before
the Commissioner will consider a request for relief under section
6015(f). Respondent agrees that in this case those threshold
conditions are satisfied.
Section 4.03 of Rev. Proc. 2000-15, 2000-1 C.B. at 448-449,
lists factors that the Commissioner will consider in deciding
whether to grant equitable relief under section 6015(f). Section
4.03(1) of Rev. Proc. 2000-15, 2000-1 C.B. at 448-449, lists the
following factors that the Commissioner will consider as weighing
in favor of granting relief for an unpaid liability: (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.
Section 4.03(2) of Rev. Proc. 2000-15, 2000-1 C.B. at 449,
lists the following factors that the Secretary will consider as
weighing against granting relief for an unpaid liability: (1)
The unpaid liability is attributable to the requesting spouse;
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Last modified: May 25, 2011