Wendlyn H. Albin - Page 19

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                    (c)  Abuse.  The requesting spouse was abused by                  
               the nonrequesting spouse, but such abuse did not amount                
               to duress.                                                             
                    (d)  No knowledge or reason to know.  In the case                 
               of a liability that was properly reported but not paid,                
               the requesting spouse did not know and had no reason to                
               know that the liability would not be paid.  In the case                
               of a liability that arose from a deficiency, the                       
               requesting spouse did not know and had no reason to                    
               know of the items giving rise to the deficiency.                       
                    (e)  Nonrequesting spouse’s legal obligation.  The                
               nonrequesting spouse has a legal obligation pursuant to                
               a divorce decree or agreement to pay the outstanding                   
               liability.  This will not be a factor weighing in favor                
               of relief if the requesting spouse knew or had reason                  
               to know, at the time the divorce decree or agreement                   
               was entered into, that the nonrequesting spouse would                  
               not pay the liability.                                                 
                    (f)  Attributable to nonrequesting spouse.  The                   
               liability for which relief is sought is solely                         
               attributable to the nonrequesting spouse.                              
          Rev. Proc. 2000-15, sec. 4.03(2), 2000-1 C.B. at 449, lists the             
          following six negative factors which weigh against granting                 
          equitable relief:                                                           
                    (a)  Attributable to the requesting spouse.  The                  
               unpaid liability or item giving rise to the deficiency                 
               is attributable to the requesting spouse.                              
                    (b)  Knowledge, or reason to know.  A requesting                  
               spouse knew or had reason to know of the item giving                   
               rise to a deficiency or that the reported liability                    
               would be unpaid at the time the return was signed.                     
               This is an extremely strong factor weighing against                    
               relief.  Nonetheless, when the factors in favor of                     
               equitable relief are unusually strong, it may be                       
               appropriate to grant relief under � 6015(f) in limited                 
               situations where a requesting spouse knew or had reason                
               to know that the liability would not be paid, and in                   
               very limited situations where the requesting spouse                    






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