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4.03(1) of Rev. Proc. 2000-15, 2000-1 C.B. at 448-449, lists the
following six 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 six 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; (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; (4) the requesting spouse will
not suffer economic hardship if relief is denied; (5) the
requesting spouse has not made a good faith effort to comply with
Federal income tax laws in the tax years following the tax year to
which the request for relief relates; and (6) the requesting spouse
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