Angela Barriga, f.k.a. Angela Robledo - Page 9

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          pursuant to a divorce decree or agreement to pay the unpaid                 
          liability; and (6) the unpaid liability is attributable to the              
          nonrequesting spouse.  Rev. Proc. 2000-15, sec. 4.03(2), 2000-1             
          C.B. at 449, lists the following six factors that the                       
          Commissioner will consider as weighing against granting relief              
          for an unpaid liability (negative factors):  (1) The unpaid                 
          liability is attributable to the requesting spouse; (2) the                 
          requesting spouse knew or had reason to know that the reported              
          liability would be unpaid at the time that the return was signed;           
          (3) the requesting spouse significantly benefited (beyond normal            
          support) from the unpaid liability; (4) the requesting spouse               
          will not suffer 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 unpaid liability.  No single factor is                 
          determinative, and the list is not exhaustive.  See Washington v.           
          Commissioner, supra at 148; Jonson v. Commissioner, supra at 125.           
               Petitioner is divorced from Robledo, and the divorce decree            
          allocates tax liabilities to Robledo.  Only those two factors               
          weigh in her favor.  Petitioner has not negated her knowledge of            
          the reported liabilities, has not shown that she would suffer               
          economic hardship if relief were denied, and has not shown that             






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