- 10 - the provisions providing relief from joint and several liability are “‘designed to protect the innocent, not the intentionally ignorant’”. Morello v. Commissioner, T.C. Memo. 2004-181 (quoting Dickey v. Commissioner, T.C. Memo. 1985-478). Petitioner has not established that she did not have reason to know the tax liabilities shown on her returns for the years at issue would not be paid when she signed them and that it was reasonable for her to believe Mr. Cowdery would pay those liabilities. Consequently, petitioner does not satisfy the knowledge or reason to know element of Rev. Proc. 2000-15, sec. 4.02 and does not qualify for equitable relief under that section of the revenue procedure. For the sake of completeness, however, we also address the economic hardship factor. 2. Economic Hardship Rev. Proc. 2000-15, sec. 4.02 requires that the determination of whether a requesting spouse will suffer economic hardship be based on rules similar to those in section 301.6343- 1(b)(4), Proced. & Admin. Regs. Rev. Proc. 2000-15, sec. 4.02(1)(c). Economic hardship is present if satisfaction of thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011