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to fulfill a duty of inquiry. The Court concludes that this
factor favors petitioner.
7. Whether the Underpayment of Tax Is Attributable to
Petitioner's Husband
Respondent concedes that the underpayment of tax for 1996 is
attributable to Mr. Keitz. The Court concludes that this factor
favors petitioner.
8. Legal Obligation To Pay Tax
During the evaluation process, respondent's examiner
determined that Mr. Keitz bears the legal obligation for the tax
liability. As neither party has introduced any additional
evidence on this point, the Court accepts this determination and
concludes that this factor favors petitioner.
9. Conclusion
Petitioner has presented a strong case for relief from joint
liability under the factors promulgated by the Commissioner in
Rev. Proc. 2000-15, supra. All of the factors except one,
economic hardship, either weigh in favor of petitioner or are
neutral. While the economic hardship factor weighs against
petitioner, it does not outweigh the positive and neutral
factors. Rev. Proc. 2000-15, sec. 4.03(2).
Petitioner is no longer married to Mr. Keitz. She did not
significantly benefit from the underpayment, the underpayment was
solely attributable to Mr. Keitz, petitioner has complied with
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