Connie A. Washington - Page 18

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          respondent’s contentions.  We now address each of these factors             
          separately.                                                                 
               1.  Requesting Spouse’s Legal Obligation Factor                        
               Petitioner’s divorce  decree  does  not  place  the  legal             
          obligation to pay the unpaid 1989 tax liability on either                   
          petitioner or her former husband.  Respondent contends that the             
          fact that Mr. Washington does not have a legal obligation under the         
          divorce decree to pay the unpaid 1989 tax liability weighs against          
          granting relief to petitioner.  Respondent’s contention is flawed.          
          Section 4.03(1)(e) of Rev. Proc. 2000-15, 2000-1 C.B. at 449,               
          indicates that if Mr. Washington had a legal obligation under the           
          divorce decree to pay the 1989 tax liability, then that fact would          
          weigh in favor of granting relief to petitioner; likewise, if the           
          divorce decree had placed the obligation to pay the tax on                  
          petitioner, then that fact would weigh against granting relief to           
          petitioner as indicated in section 4.03(2)(f) of Rev. Proc. 2000-           
          15, 2000-1 C.B. at 449.  But here, the divorce decree did not               
          establish whose (petitioner’s or Mr. Washington’s) obligation it            
          was to pay the unpaid 1989 tax liability.  Therefore, this is a             
          neutral factor.                                                             
               2.  Abuse Factor                                                       
               Petitioner does not assert that she was abused by Mr.                  
          Washington or otherwise coerced into executing the 1989 joint               
          return.  However, in response to questioning by respondent’s                






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