Vernon Stacy Taylor - Page 6

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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          Proc. 2000-15, supra, has been superseded by Rev.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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