Ruth E. Neal - Page 15

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          v. Commissioner, 118 T.C. 494, 506-507 (2002), we held that we                
          have jurisdiction to review claims for section 6015(f) relief                 
          similar to petitioner’s claim.                                                
               Under section 6015(f), whether it would be inequitable for a             
          requesting spouse to be held jointly liable for unpaid taxes                  
          “requires a careful consideration of all possible factors that                
          are relevant” to the inquiry.  Alt v. Commissioner, 101 Fed.                  
          Appx. 34, 39-40 (6th Cir. 2004) (quoting Silverman v.                         
          Commissioner, 116 F.3d 172, 175 (6th Cir. 1997), revg. T.C. Memo.             
          1996-69), affg. 119 T.C. 306 (2002).                                          
               Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. 447, 448-449,                 
          sets forth guidelines or factors to consider in deciding claims               
          for equitable relief under section 6015(f) as follows:                        

                    (1) Whether the requesting spouse will suffer economic              
               hardship;                                                                
                    (2) Whether the requesting spouse, at the time the                  
               return was signed, had knowledge or reason to know that the              
               liability reported on the return would not be paid;                      
                    (3) Whether the nonrequesting spouse has a legal                    
               obligation to pay the unpaid joint Federal income taxes;                 
                    (4) Whether the underpayments of joint Federal income               
               taxes are attributable to the nonrequesting spouse;                      
                    (5) Whether the spouses are separated or divorced;                  
                    (6) Whether the requesting spouse suffered abuse by the             
               nonrequesting spouse;                                                    
                    (7) Whether the requesting spouse received significant              
               benefit, beyond normal support, as a result of the                       
               underpayments of joint Federal income taxes; and                         





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