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reduced if petitioner’s wages had been properly reported on the
return.
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
minimal.
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.
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