Maureen Monsour - Page 50

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          that revenue procedure, on which she also relies in support of her          
          claim for relief with respect to each of the taxable years 1989,            
          1991, 1992, and 1993.                                                       
               Section 4.03 of Revenue Procedure 2000-15 provides a partial           
          list of positive and negative factors which respondent is to take           
          into account in considering whether respondent will grant an                
          individual full or partial equitable relief under section 6015(f).          
          As Revenue Procedure 2000-15 makes clear, no single factor is to            
          be determinative in any particular case, all factors are to be              
          considered and weighed appropriately, and the list of factors is            
          not intended to be exhaustive.  Rev. Proc. 2000-15 sec. 4.03,               
          2000-1 C.B. 447, 448.                                                       
               We turn now to the application of section 4.03 of Revenue              
          Procedure 2000-15 to this case.  Section 4.03(1) of Revenue                 
          Procedure 2000-15 sets forth the following positive factors which           
          weigh in favor of granting relief under section 6015(f):                    
                    (a) Marital status.  The requesting spouse is                     
               separated * * * or divorced from the nonrequesting                     
               spouse.                                                                
                    (b) Economic hardship.  The requesting spouse would               
               suffer economic hardship (within the meaning of section                
               4.02(1)(c) of this revenue procedure) if relief from the               
               liability is not granted.                                              
                    (c) Abuse.  The requesting spouse was abused by the               
               nonrequesting spouse, but such abuse did not amount to                 
               duress.                                                                
                    (d) No knowledge or reason to know.  In the case of               
               a liability that was properly reported but not paid, the               
               requesting spouse did not know and had no reason to know               





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