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available to petitioner under section 6015(b) or (c), he 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, 2000-1 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, sec. 4.02
sets forth the circumstances under which the Commissioner will
ordinarily grant relief to that spouse under section 6015(f).
Respondent determined that petitioner has not shown that, at
the time the return was signed, he had no knowledge or reason to
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, Aug. 12, 2002. Rev.
Proc. 2000-15, supra, has been superseded by Rev. Proc. 2003-61,
2003-32 I.R.B. 296, effective for requests for relief filed on or
after Nov. 1, 2003.
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Last modified: May 25, 2011