Nancy M. O'Neill, Petitioner, and Robert B. Wollow, Intervenor - Page 7

                                        - 7 -                                         
          Cir. 2003).  Moreover, the list of factors is not intended to be            
          exhaustive.  See Washington v. Commissioner, supra at 148.                  
               The following six factors weigh in favor of granting relief            
          for the liability:  (1) The requesting spouse is separated or               
          divorced from the nonrequesting spouse; (2) the requesting spouse           
          would suffer economic hardship if relief is denied; (3) the                 
          nonrequesting spouse abused the requesting spouse; (4) the                  
          requesting spouse did not know or have reason to know that the              
          liability would not be paid; (5) the nonrequesting spouse has a             
          legal obligation pursuant to a divorce decree or agreement to pay           
          the liability; and (6) the liability is solely attributable to              
          the nonrequesting spouse.  See Rev. Proc. 2000-15, sec. 4.03(1),            
          2000-1 C.B. at 448-449.  On the other hand, the following six               
          factors weigh against granting relief for the liability:  (1) The           
          unpaid liability is attributable to the requesting spouse; (2)              
          the requesting spouse knew or had reason to know when she signed            
          the return that the reported liability would be unpaid; (3) the             
          requesting spouse significantly benefited (beyond the normal                
          support) from the unpaid liability; (4) the requesting spouse               
          will not experience economic hardship if relief is denied; (5)              
          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 to which the request for relief relates; and (6) the                   
          requesting spouse had a legal obligation pursuant to a divorce              






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