Donna M. Keitz - Page 15

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          properly reported but not paid, the taxpayer did not know and had           
          no reason to know that the liability would not be paid; (7) the             
          liability for which relief is sought is attributable to the                 
          nonrequesting spouse; and (8) the nonrequesting spouse has a                
          legal obligation pursuant to a divorce decree or agreement to pay           
          the outstanding liability (weighs against relief only if the                
          requesting spouse has the obligation).  Ewing v. Commissioner,              
          supra at ____ (slip op. at 22-24).                                          
               Rev. Proc. 2000-15, sec. 4.03(2), states that "No single               
          factor will be determinative of whether equitable relief will or            
          will not be granted in any particular case.  Rather, all factors            
          will be considered and weighed appropriately.  The list is not              
          intended to be exhaustive."                                                 
               As discussed next, most of the factors the Commissioner uses           
          in making section 6015(f) determinations do not support                     
          respondent's determination in this case.                                    
               1.   Petitioner's Marital Status                                       
               Respondent determined that the marital status factor weighs            
          in favor of petitioner.  As discussed, supra, the Court agrees              
          that this factor favors petitioner.                                         
               2.   Spousal Abuse                                                     
               Mr. Keitz did not abuse petitioner.  Lack of spousal abuse             
          is not a factor listed in Rev. Proc. 2000-15, sec. 4.03(2), that            
          weighs against granting equitable relief.  Washington v.                    






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