Connie A. Washington - Page 22

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               During petitioner’s marriage to Mr. Washington, petitioner             
          paid the tax on her wages through withholding, and Mr. Washington           
          paid the taxes attributable to his business.  Mr. Washington                
          controlled all aspects of his business, and he conducted his                
          business affairs without any assistance or involvement from                 
          petitioner.  The record and petitioner’s credible testimony                 
          demonstrate that petitioner had no knowledge of, or involvement in,         
          her former husband’s business.  (We found petitioner to be credible         
          after having observed her appearance and demeanor at trial.)  We            
          conclude that petitioner had no knowledge or reason to know at the          
          time the returns were signed that the reported liability would not          
          be paid by Mr. Washington.                                                  
               Assuming arguendo that petitioner had reason to know that the          
          reported 1989 tax liability would not be paid, other factors in             
          favor of granting petitioner equitable relief are unusually strong          
          in this case.  And “when the factors in favor of equitable relief           
          are unusually strong, it may be appropriate to grant relief under           
          section 6015(f) in limited situations where the requesting spouse           
          knew or had reason to know that the liability would not be paid”.           
          Rev. Proc. 2000-15, sec. 4.03(2)(b), 2000-1 C.B. at 449.  Thus,             
          even if petitioner knew or had reason to know that the reported             
          liability would not be paid, on the basis of all the facts and              
          circumstances of this case, we find that compelling reasons existed         
          for respondent to grant petitioner equitable relief.                        






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