- 18 - 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 incomePage: 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