Nancy M. O'Neill, Petitioner, and Robert B. Wollow, Intervenor - Page 6

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          for relief from joint and several liability under section                   
          6015(f).4  We review the Commissioner’s denial of relief under              
          section 6015(f) for abuse of discretion.  See Washington v.                 
          Commissioner, 120 T.C. 137, 146 (2003); Butler v. Commissioner,             
          supra at 292.                                                               
               Before the Commissioner will consider a taxpayer’s request             
          for relief under section 6015(f), the taxpayer must satisfy seven           
          threshold conditions listed in Rev. Proc. 2000-15, sec. 4.01,               
          2000-1 C.B. at 448.  Respondent concedes that petitioner                    
          satisfies these conditions.                                                 
               Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, provides            
          that equitable relief may be granted under section 6015(f) if,              
          taking into account all facts and circumstances, it is                      
          inequitable to hold the requesting spouse liable.  In considering           
          a request for relief, certain factors weigh in favor of granting            
          relief, whereas other factors weigh against granting relief.  See           
          id.  No single factor is determinative in any particular case,              
          and all factors are to be considered and weighed appropriately.             
          See Washington v. Commissioner, supra at 148; Jonson v.                     
          Commissioner, 118 T.C. 106, 125 (2002), affd. 353 F.3d 1181 (10th           

               4On Aug. 11, 2003, the Commissioner issued Rev. Proc. 2003-            
          61, 2003-32 I.R.B. 296, which supersedes Rev. Proc. 2000-15,                
          2000-1 C.B. 447, effective for requests for relief filed on or              
          after Nov. 1, 2003, and for requests for relief pending on Nov.             
          1, 2003, for which no preliminary determination letter has been             
          issued as of that date.                                                     

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