Zenobia Elisia Clary Ziegler - Page 12

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          support) from the unpaid liability; (4) the requesting spouse               
          will not experience 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 has a legal obligation pursuant to a divorce              
          decree or agreement to pay the liability.  No single factor is              
          determinative in any particular case; all factors are to be                 
          considered and weighed appropriately; and the list of factors is            
          not intended to be exhaustive.  See Washington v. Commissioner,             
          120 T.C. at 148; Jonson v. Commissioner, 118 T.C. 106, 125                  
               Respondent argues that petitioner is not eligible for relief           
          under section 6015(f) because the negative factors in Rev. Proc.            
          2000-15, supra, outweigh the positive factors in that revenue               
          procedure.  Respondent primarily relies on the following:                   
          Petitioner will not suffer economic hardship if she is denied               
          relief; petitioner’s income is the sole basis for the deficiency;           
          and petitioner knew that her earned income was not included on              
          the 1998 joint return.  On the basis of our review of the record            
          in this case, we agree with respondent.                                     
               The record is devoid of any evidence demonstrating that                
          petitioner will experience any economic hardship if relief from             
          the liability is not granted.  Petitioner did not offer any proof           

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