- 36 - Prior to the time she signed the returns for 1996 through 1999, petitioner (1) knew respondent had taken collection actions for 1979 involving levies upon Levy’s accounts during March and April of 1997, and (2) had signed a tax collection waiver on May 22, 1997, showing that she and Levy still owed an unpaid tax liability of more than $49,000 for 1979. We conclude that petitioner had reason to know that Levy would not pay the 1996 through 1999 balance due amounts at the time she signed the returns for those years. See Knorr v. Commissioner, T.C. Memo. 2004-212. This factor weighs in favor of granting petitioner relief for 1991 through 1995, but weighs against granting petitioner relief for 1996 through 1999. 5. Significant Benefit Factor Rev. Proc. 2000-15, sec. 4.03(2)(c), 2000-1 C.B. at 448, provides that the requesting spouse significantly benefiting (beyond normal support) from the unpaid liability is a factor weighing against granting her relief. Section 4.03(2)(c) of Rev. Proc. 2000-15, supra, references former section 1.6013-5(b), Income Tax Regs., for purposes of determining whether the requesting spouse received a significant benefit.15 Although 15 Former sec. 1.6013-5(b), Income Tax Regs. (Aug. 5, 1974), provided, in pertinent part: In making such a determination a factor to be (continued...)Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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