Louise Demirjian - Page 16

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          of granting relief and that, if not true, are neutral:  (1) The             
          taxpayer is separated or divorced from the nonrequesting spouse             
          and (2) the taxpayer was abused by his or her spouse.  Respondent           
          concedes that the marital status factor weighs in favor of                  
          petitioner.  The abuse factor is neutral in this case because               
          petitioner failed to provide any evidence establishing abuse.               
               In addition, Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at             
          448, lists the following two factors that, if true, respondent              
          weighs against granting relief and that, if not true, are                   
          neutral:  (1) The taxpayer received a significant benefit from              
          the unpaid liability or the item giving rise to the deficiency              
          and (2) the taxpayer has not made a good faith effort to comply             
          with the Federal income tax laws in the tax years following the             
          tax year to which the request for relief relates.  The                      
          significant benefit factor is neutral in this case because                  
          petitioner ultimately paid the 1989 income tax liability.  The              
          noncompliance factor is also neutral in this case because both              
          parties failed to argue or present evidence as to whether                   
          petitioner has made a good faith effort to comply with the                  
          Federal income tax laws since 1989.                                         
               Finally, Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448,            
          lists the following four factors that, if true, respondent weighs           
          in favor of granting relief and that, if not true, respondent               
          weighs against granting relief:  (1) The taxpayer would suffer              






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