Susan L. Abelein - Page 34

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               In accordance with the above, we shall consider each of the            
          positive and negative factors enumerated in Rev. Proc. 2000-15,             
          sec. 4.03.  We shall also consider whether any additional facts             
          alleged by the parties affect the analysis of whether respondent            
          abused his discretion in denying petitioner equitable relief                
          under section 6015(f).                                                      
               1.  Positive Factors                                                   
                    a.  Marital Status                                                
               Petitioner is still married and living with Mr. Abelein.               
          Consequently, this positive factor does not apply.  Ewing v.                
          Commissioner, supra at 46.                                                  
                    b.  Economic Hardship                                             
               An analysis of economic hardship under Rev. Proc. 2000-15,             
          supra, is conducted using rules similar to those under section              
          301.6343-1(b)(4), Proced. & Admin. Regs., and focuses on the                
          requesting spouse’s inability to pay reasonable basic living                
          expenses.  Rev. Proc. 2000-15, sec. 4.02(1)(c).  Section                    
          301.6343-1(b)(4)(ii), Proced. & Admin. Regs., provides that the             
          Commissioner will evaluate a requesting spouse’s claim of                   
          economic hardship by considering any information offered by the             
          requesting spouse that is relevant to the determination,                    
          including, but not limited to, the requesting spouse’s income,              
          assets and liabilities, age, ability to earn, responsibility for            








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