Brenda Wallace - Page 6

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          the denial of equitable relief by the IRS was an abuse of                   
          discretion.  Washington v. Commissioner, supra at 146; Jonson v.            
          Commissioner, 118 T.C. 106, 125 (2002); Cheshire v. Commissioner,           
          115 T.C. 183 (2000), affd. 282 F.3d 326 (5th Cir. 2002).                    
               Pursuant to section 6015(f), the Commissioner has prescribed           
          guidelines setting forth various factors considered in                      
          determining whether a taxpayer is entitled to equitable relief              
          under section 6015(f).  Rev. Proc. 2000-15, 2000-1 C.B. 447.                
          Among the factors against granting of relief are:  (1) The unpaid           
          liability is attributable to the requesting spouse; (2) the                 
          requesting spouse knew or had reason to know that the reported              
          liability would be unpaid at the time the return was signed; (3)            
          the requesting spouse significantly benefited (beyond normal                
          support) from the unpaid liability; and (4) the requesting spouse           
          will not suffer economic hardship if relief is denied.                      
               Petitioner has failed to establish that there was an abuse             
          of discretion by respondent in denying her relief under section             
          6015(f).  Her sole argument is that, at the time the amended                
          return was filed in 1998, she was unemployed and did not have the           
          assets or resources to pay the tax.  She had previously been                
          employed, and, although she may have been unemployed at the time            
          the amended return was filed, she thereafter resumed employment.            








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