- 15 - 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; andPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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