Ann Marie Bright - Page 14

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          petitioner introduced no evidence of her basic living expenses or           
          other current debts that would show she could not pay her current           
          reasonable basic living expenses.  Accordingly, petitioner has              
          failed to establish that she will suffer economic hardship if               
          equitable relief is not granted.  The Court concludes that                  
          petitioner has not satisfied this element.  Therefore, the Court            
          concludes that petitioner fails to qualify for relief under Rev.            
          Proc. 2000-15, sec. 4.02.                                                   
               If the requesting spouse satisfies the threshold conditions            
          of Rev. Proc. 2000-15, sec. 4.01, but does not qualify for relief           
          under Rev. Proc. 2000-15, sec. 4.02, the Commissioner looks to              
          Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, to determine             
          whether the taxpayer should be granted equitable relief.                    
               Rev. Proc. 2000-15, sec. 4.03(1), lists the following six              
          factors weighing in favor of granting relief for an unpaid                  
          liability:  (1) The requesting spouse is separated or divorced              
          from the nonrequesting spouse; (2) the requesting spouse will               
          suffer economic hardship if relief is denied; (3) the requesting            
          spouse was abused by the nonrequesting spouse; (4) the requesting           
          spouse did not know or have reason to know that the reported                
          liability would not be paid; (5) the nonrequesting spouse has a             
          legal obligation pursuant to a divorce decree or agreement to pay           
          the unpaid liability; and (6) the unpaid liability is                       
          attributable to the nonrequesting spouse.  Rev. Proc. 2000-15,              






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