Mary A. George - Page 7

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          the Secretary will consider any request for equitable relief                
          pursuant to section 6015(f).  In the instant case, respondent               
          concedes that petitioner satisfied the seven threshold                      
          conditions.                                                                 
               Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, provides            
          that equitable relief will ordinarily be granted if the seven               
          threshold conditions and each of the following three elements               
          (collectively referred to hereinafter as the three elements) are            
          satisfied:                                                                  
                    (a) At the time relief is requested, the                          
               requesting spouse is no longer married to, or is                       
               legally separated from, the nonrequesting spouse, or                   
               has not been a member of the same household as the                     
               nonrequesting spouse at any time during the 12-month                   
               period ending on the date relief was requested [the                    
               first element];                                                        
                    (b) At the time the return was signed, the                        
               requesting spouse had no knowledge or reason to know                   
               that the tax would not be paid.  The requesting spouse                 
               must establish that it was reasonable for the                          
               requesting spouse to believe that the nonrequesting                    
               spouse would pay the reported liability.  If a                         
               requesting spouse would otherwise qualify for relief                   
               under this section, except for the fact that the                       
               requesting spouse had no knowledge or reason to know of                
               only a portion of the unpaid liability, then the                       
               requesting spouse may be granted relief only to the                    
               extent that the liability is attributable to such                      
               portion [the second element]; and                                      
                    (c) The requesting spouse will suffer economic                    
               hardship if relief is not granted.  For purposes of                    
               this section, the determination of whether a requesting                

               2(...continued)                                                        
                    (7) The requesting spouse did not file the return with            
               fraudulent intent.                                                     





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