Tammy Debra Martin - Page 5

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          underpayments is not available to petitioner under section                  
          6015(b) or (c), she has satisfied one of the two prerequisites              
          for relief under section 6015(f).                                           
               The other prerequisite is that it is inequitable to hold the           
          individual liable for the unpaid tax, taking into consideration             
          all of the facts and circumstances.  As contemplated by section             
          6015(f), the Commissioner has prescribed guidelines in Rev. Proc.           
          2000-15, sec. 4.02, 2000-1 C.B. 447, 448, to be used in                     
          determining whether an individual qualifies for relief under that           
          section.2  Rev. Proc. 2000-15, sec. 4.01, 2001-1 C.B. at 448,               
          sets forth the threshold conditions that must be satisfied before           
          the Commissioner will consider a request for equitable relief               
          under section 6015(f).  Respondent does not dispute that                    
          petitioner has satisfied the threshold conditions.                          
               Where the requesting spouse satisfies the threshold                    
          conditions set forth in Rev. Proc. 2000-15, sec. 4.01, Rev. Proc.           
          2000-15, sec. 4.02 sets forth the circumstances under which the             
          Commissioner will ordinarily grant relief to that spouse under              
          section 6015(f).                                                            




               2The guidelines applicable herein are set forth in Rev.                
          Proc. 2000-15, 2000-1 C.B. 447, which was in effect at the time             
          petitioner’s request for relief was made, Oct. 15, 2003.  Rev.              
          Proc. 2000-15, supra, has been superseded by Rev. Proc. 2003-61,            
          2003-2 C.B. 296, effective for requests for relief filed on or              
          after Nov. 1, 2003.                                                         





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