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Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448, sets
forth seven threshold conditions2 that must be satisfied before
2Section 4. General Conditions for Relief
.01 Eligibility to be considered for equitable relief. All
the following threshold conditions must be satisfied before the
Service will consider a request for equitable relief under
� 6015(f). * * * The threshold conditions are as follows:
(1) The requesting spouse filed a joint return for the
taxable year for which relief is sought;
(2) Relief is not available to the requesting spouse
under � 6015(b) or 6015(c);
(3) The requesting spouse applies for relief no later
than two years after the date of the Service’s first
collection activity after July 22, 1998, with respect to the
requesting spouse;
(4) Except as provided in the next sentence, the
liability remains unpaid. A requesting spouse is eligible
to be considered for relief in the form of a refund of
liabilities for: (a) amounts paid on or after July 22,
1998, and on or before April 15, 1999; and (b) installment
payments, made after July 22, 1998, pursuant to an
installment agreement entered into with the Service and with
respect to which an individual is not in default, that are
made after the claim for relief is requested;
(5) No assets were transferred between the spouses
filing the joint return as part of a fraudulent scheme by
such spouses;
(6) There were no disqualified assets transferred to
the requesting spouse by the nonrequesting spouse. If there
were disqualified assets transferred to the requesting
spouse by the nonrequesting spouse, relief will be available
only to the extent that the liability exceeds the value of
such disqualified assets. For this purpose, the term
“disqualified asset” has the meaning given such term by �
6015(c)(4)(B); and
(continued...)
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