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2. Negative Factors
a. Attributable to the Requesting Spouse
Because the unpaid liabilities are attributable to both
petitioner and Mr. Cowdery, this factor weighs against granting
petitioner equitable relief.
b. Knowledge or Reason To Know
As discussed, supra, we conclude that petitioner had reason
to know when she signed the returns that the tax liabilities
would not be paid. This factor weighs heavily against granting
petitioner equitable relief. Rev. Proc. 2000-15, sec.
4.03(2)(b).
c. Significant Benefit
Respondent does not contend that petitioner significantly
benefited from the unpaid liabilities, and the record does not
reflect otherwise. This factor weighs in favor of granting
petitioner equitable relief.
d. Lack of Economic Hardship
As discussed, supra, petitioner has failed to establish that
she will suffer economic hardship if relief is not granted.
This negative factor applies and weighs against granting relief.
e. Noncompliance With Federal Income Tax Laws in
Subsequent Years
Respondent does not contend that this factor applies, and he
did not otherwise argue on brief or at trial that petitioner did
not make a good-faith effort to comply with her Federal income
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