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liability in question. Section 4.01 of Revenue Procedure 2000-15
lists seven conditions (threshold conditions) which must be
satisfied before the IRS will consider a request for relief under
section 6015(f). In the instant case, respondent concedes that
those conditions are satisfied. Where, as here, the requesting
spouse satisfies the threshold conditions, section 4.01 of
Revenue Procedure 2000-15 provides that a requesting spouse may
be relieved under section 6015(f) of all or part of the liability
in question if, taking into account all the facts and circum-
stances, the IRS determines that it would be inequitable to hold
the requesting spouse liable for such liability.
Where, as here, the requesting spouse satisfies the thresh-
old conditions, section 4.02(1) of Revenue Procedure 2000-15 sets
forth the circumstances under which the IRS ordinarily will grant
relief to that spouse under section 6015(f) in a case, like the
instant case, where a liability is reported in a joint return but
not paid. As pertinent here, those circumstances, which section
4.02 of Revenue Procedure 2000-15 and we refer to as elements,
are:
(a) At the time relief is requested, the request-
ing spouse is no longer married to * * * the
nonrequesting spouse * * *;
(b) At the time the return was signed, the re-
questing spouse had no knowledge or reason to know that
the tax would not be paid. The requesting spouse must
establish that it was reasonable for the requesting
spouse to believe that the nonrequesting spouse would
pay the reported liability. * * *; and
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