Kathleen E. Gilliam - Page 10

                                        - 9 -                                         
          reduced if petitioner’s wages had been properly reported on the             
               iv.  Lack of Economic Hardship                                         
               It appears that petitioner does suffer from some economic              
          hardship and no doubt will suffer further if she is not relieved            
          of the liability.  Her income in subsequent years appears to be             
               v.  Noncompliance With Federal Income Tax Laws                         
               The requesting spouse must make a good faith effort to                 
          comply with Federal income tax laws in the tax years following              
          the tax year or years to which the request for relief relates.              
          In the present case, the record is silent on this issue.                    
               vi.  Requesting Spouse’s Legal Obligation                              
               Petitioner did not have any legal obligation pursuant to a             
          divorce decree to pay the liability.                                        
               b.  Factors In Favor of Relief                                         
               Counterbalancing the factors weighing against relief are the           
          factors weighing in favor of relief.  We next review each of the            
          following six factors, as listed under Rev. Proc. 2000-15, sec.             
          4.03(1), to evaluate whether they serve as a makeweight for                 
          equitable relief under section 6015(f).                                     
               i.  Marital Status                                                     
               Petitioner is separated and divorced from Mr. Gilliam.                 

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011