Ingrid Capehart - Page 47

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          evidence of her current financial condition, we conclude that               
          requiring petitioner to pay the liabilities allocated to her                
          under section 6015(c) would not result in economic hardship as              
          that term is defined under Rev. Proc. 2000-15.  Consequently,               
          this factor applies and weighs against granting petitioner                  
          equitable relief in our analysis.                                           
                    e.  Noncompliance With Federal Income Tax Laws in                 
                    Subsequent Years                                                  
               Respondent did not determine that this factor applies and              
          weighs against granting petitioner equitable relief.  Moreover,             
          respondent does not argue in his posttrial briefs that petitioner           
          did not make a good faith effort to comply with her Federal                 
          income tax obligations in years subsequent to the ones at issue             
          here.  Consequently, we conclude that this factor does not apply,           
          and we treat it as neutral in our analysis.                                 
                    f.  Requesting Spouse’s Legal Obligation                          
               With respect to the positive counterpart of this factor, we            
          concluded that petitioner and Mr. Capehart were married during              
          all relevant times, that they were not divorced when Mr. Capehart           
          died, and that neither petitioner nor Mr. Capehart had assumed              
          sole responsibility to pay the liabilities at issue in this case.           
          These conclusions also dictate our treatment of this factor.                
          Because petitioner was not solely responsible for paying the                
          liabilities at issue in this case, this factor does not apply,              
          and we treat it as neutral in our analysis.                                 





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