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the instant case.
With respect to the legal obligation negative factor set
forth in section 4.03(2)(f) of Revenue Procedure 2000-15, we have
found that, because petitioner concedes that Mr. Simon does not
have a legal obligation to pay any tax due for 1998, petitioner
concedes that the legal obligation positive factor set forth in
section 4.03(1)(e) of that revenue procedure is not present in
the instant case. We have also found that there is no separate
legal obligation, such as a divorce decree or a property settle-
ment, that requires petitioner to pay any such tax due.13 On the
record before us, we find that the legal obligation negative
factor is not present in the instant case.
On the record before us, we find that petitioner has failed
to carry her burden of establishing any other factors that weigh
in favor of granting relief under section 6015(f) and that are
not set forth in sections 4.02(1) and 4.03(1) of Revenue Proce-
dure 2000-15.
Based upon our examination of the entire record before us,
we find that petitioner has failed to carry her burden of showing
that respondent abused respondent’s discretion in denying her
relief under section 6015(f) with respect to the unpaid 1998
liability.
13Division of the marital assets of petitioner and Mr. Simon
remains to be adjudicated by the North Carolina courts.
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