Andrea J. Vuxta - Page 10

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               f.  Requesting Spouse’s Legal Obligation                               
               The record is also devoid of any information regarding                 
          whether petitioner has a legal obligation pursuant to a divorce             
          decree or agreement to pay the liability.                                   
               Counterbalancing the factors weighing against relief are the           
          factors weighing in favor of relief.  We next review each of the            
          following six factors, as listed under Rev. Proc. 2000-1, sec.              
          4.03(1), to evaluate whether they serve as a makeweight for                 
          equitable relief under section 6015(f):                                     
               a.  Marital Status                                                     
               Petitioner is separated or divorced from Mr. Vuxta.  He died           
          on May 4, 2001, a year before petitioner made her request for               
          relief from joint and several liability.  This factor is squarely           
          in favor of petitioner.                                                     
               b.  Economic Hardship                                                  
               As we indicated earlier, petitioner has not shown that she             
          will suffer economic hardship if relief is not granted.                     
               c.  Abuse                                                              
               There is nothing in the record indicating that petitioner              
          was subject to abuse.                                                       
               d.  No Knowledge or Reason To Know                                     
               As we indicated earlier, petitioner knew or had reason to              
          know that the reported liabilities for 1990 and 1991 would be               
          unpaid at the time the corresponding returns were signed.                   






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