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4.03 of Rev. Proc. 2000-15 to review respondent’s denial of
relief for an abuse of discretion.
Section 4.03 of Rev. Proc. 2000-15 provides a nonexhaustive
list of factors that the Commissioner is to take into account in
determining whether to grant full or partial relief under section
6015(f). The revenue procedure provides that no single factor is
to be determinative; rather, all factors are to be considered and
weighted appropriately. Section 4.03(1) of Rev. Proc. 2000-15
lists six factors that, if present, the Commissioner will
consider as weighing in favor of granting relief for an unpaid
liability (positive factors), and section 4.03(2), 2000-1 C.B. at
449, lists six factors that, if present, the Commissioner will
consider as weighing against granting relief for an unpaid
liability (negative factors). The following are the positive
factors set forth in the revenue procedure, as they apply to this
case:
(a) Marital status. The requesting spouse is * * *
divorced from the nonrequesting spouse.
(b) Economic hardship. The requesting spouse would
suffer economic hardship (within the meaning of section
4.02(1)(c) of this revenue procedure) if relief from the
liability is not granted.
(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 arose from a deficiency, the requesting
spouse did not know and had no reason to know of the items
giving rise to the deficiency.
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