- 13 - only argument against granting equitable relief is that petitioner knew or had reason to know that the taxes would not be paid. When the factors in favor of equitable relief are unusually strong, it may be appropriate to grant relief under section 6015(f) in limited situations where the requesting spouse knew or had reason to know that the liability would not be paid. Washington v. Commissioner, supra at 151; Rev. Proc. 2000-15, sec. 4.03(2)(b), 2000-1 C.B. at 449. Additionally, we have previously considered the fact that a taxpayer did not significantly benefit from the unpaid liability as a factor in favor of granting relief to that taxpayer. Ewing v. Commissioner, 122 T.C. ___, ___ (2004) (slip op. at 22-23); Ferrarese v. Commissioner, T.C. Memo. 2002-249; Rowe v. Commissioner, T.C. Memo. 2001-325. The factors listed in Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448-449, are not exhaustive, and all facts and circumstances must be taken into account in determining whether it would be inequitable to hold a requesting spouse liable. Ewing v. Commissioner, 122 T.C. at ___ (slip op. at 28). Petitioner presented a strong case during her dealings with respondent and at trial for equitable relief from joint and several liability under the factors promulgated by the Commissioner in Rev. Proc. 2000-15, supra, and other relevantPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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