Wendlyn H. Albin - Page 21

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          essentially the opposite of the attribution factor in Rev. Proc.            
          2000-15, sec. 4.03(1)(f),                                                   
               a.  Positive Factors                                                   
                    i.  Marital Status                                                
               Petitioner does not claim that this factor favors her                  
          position.  Nor do we find that such is the case.  Petitioner is             
          neither separated nor divorced from Albin.  We hold that this               
          factor does not weigh in favor of granting equitable relief to              
          petitioner for any of the subject years.  Because Rev. Proc.                
          2000-15, supra, states that this factor will only serve to weigh            
          in favor of granting relief when it is met, and fails to state              
          that this factor will weigh against granting relief when it is              
          not met, we consider this factor neutral.                                   
                    ii.  Economic Hardship                                            
               Petitioner argues that she will suffer economic hardship if            
          equitable relief is not granted to her for each of the subject              
          years.  Petitioner argues that a decision adverse to her in this            
          case will force her to sell all of her assets so that she may pay           
          the liabilities in issue and may even result in her incurring a             
          new liability for taxes due on any capital gain that she realizes           
          on the sale.                                                                
               In determining whether a requesting spouse will suffer                 
          economic hardship, Rev. Proc. 2000-15, sec. 4.02(1)(c), to which            
          Rev. Proc. 2000-15, sec. 4.03(1)(b), refers, requires reliance on           






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