Jeanine T. Foor - Page 13

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          only argument against granting equitable relief is that                     
          petitioner knew or had reason to know that the taxes would not be           
               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 relevant               

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