Connie A. Washington - Page 17

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          has a legal obligation pursuant to a divorce decree or agreement to         
          pay the unpaid liability.  In addition, Rev. Proc. 2000-15, sec.            
          4.03, 2000-1 C.B. at 448-449, states: “No single factor will be             
          determinative of whether equitable relief will or will not be               
          granted in any particular case.  Rather, all factors will be                
          considered and weighed appropriately.”  Furthermore, the list of            
          aforementioned factors is not intended to be exhaustive.                    
               In deciding whether respondent’s determination that petitioner         
          is not entitled to relief under section 6015(f) was an abuse of             
          discretion, we consider evidence relating to all the facts and              
          circumstances.                                                              
               With regard to the case herein, respondent acknowledges that           
          the following two factors weigh in favor of granting relief to              
          petitioner:  Petitioner is divorced, and the liability for which            
          relief is sought is attributable to petitioner’s former husband.            
               Respondent contends:  (1) Petitioner knew or had reason to             
          know that her 1989 income tax was not paid at the time the return           
          was filed; (2) petitioner was not abused by her former husband; (3)         
          petitioner’s former husband did not have a legal obligation under           
          the divorce decree to pay the unpaid 1989 tax liability; and (4)            
          petitioner would not experience an economic hardship if she is not          
          relieved from the liability.  Respondent asserts that these factors         
          weigh against granting relief to petitioner.  We disagree with              








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