- 63 - relief are unusually strong, it may be appropriate to grant relief under � 6015(f) in limited situations where a requesting spouse knew or had reason to know that the liability would not be paid, and in very limited situa- tions where the requesting spouse knew or had reason to know of an item giving rise to a deficiency. (c) Significant benefit. The requesting spouse has significantly benefitted (beyond normal support) from the unpaid liability or items giving rise to the defi- ciency. See � 1.6013-5(b). (d) Lack of economic hardship. The requesting spouse will not experience economic hardship (within the meaning of section 4.02(1)(c) of this revenue procedure) if relief from the liability is not granted. (e) Noncompliance with federal income tax laws. The requesting spouse has not made 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. (f) Requesting spouse’s legal obligation. The requesting spouse has a legal obligation pursuant to a divorce decree or agreement to pay the liability. (We shall hereinafter refer to the negative factors set forth in section 4.03(2)(a), (b), (c), (d), (e), and (f) of Revenue Proce- dure 2000-15 as the attribution negative factor, the knowledge or reason to know negative factor, the significant benefit negative factor, the economic hardship negative factor, the noncompliance negative factor, and the legal obligation negative factor, respec- tively.) The parties do not dispute that the knowledge or reason to know negative factor, the economic hardship negative factor, and the legal obligation negative factor set forth in section 4.03(2)(b), (d), and (f), respectively, of Revenue ProcedurePage: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 Next
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