Yvonne C. Lopez - Page 8

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               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.                                                 
          A.   Revenue Procedure 2000-15, Section 4.02                                
               Rev. Proc. 2000-15, sec. 4.02(1), 2000-1 C.B. at 448,                  
          provides that equitable relief will ordinarily be granted as to             
          unpaid liabilities if the seven threshold conditions and each of            
          the following three elements are satisfied:                                 
                    (a) At the time relief is requested, the                          
               requesting spouse is no longer married to * * * the                    
               nonrequesting spouse * * *;                                            
                    (b) At the time the return was signed, the                        
               requesting spouse had no knowledge or reason to know                   
               that the tax would not be paid.  The requesting spouse                 
               must establish that it was reasonable for the                          
               requesting spouse to believe that the nonrequesting                    
               spouse would pay the reported liability.  * * *; and                   
                    (c) The requesting spouse will suffer economic                    
               hardship if relief is not granted.  * * *                              
          Relief under Rev. Proc. 2000-15, sec. 4.02 is only available,               
          however, to the extent that the unpaid liability is allocable to            
          the nonrequesting spouse.  Rev. Proc. 2000-15, sec. 4.02(2)(b).             
               Respondent concedes that petitioner satisfied the first                
          element because she was divorced from Mr. Cowdery at the time she           
          requested relief.  The parties, however, dispute whether                    
          petitioner satisfied the second and third elements.                         






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