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satisfied before the Commissioner will consider a request for
relief under section 6015(f). Respondent concedes that
petitioner meets these threshold conditions for equitable
innocent spouse relief.
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, lists
nonexclusive factors that the Commissioner will consider in
determining whether, taking into account all the facts and
circumstances, it is inequitable to hold the requesting spouse
liable for all or part of the unpaid income tax liability
or deficiency, and full or partial equitable relief under section
6015(f) should be granted. Rev. Proc. 2000-15, sec. 4.03(1),
provides that the following factors weigh in favor of the
Commissioner’s granting equitable relief: (1) Marital status,
(2) economic hardship, (3) abuse, (4) no knowledge or reason to
know, (5) nonrequesting spouse’s legal obligation, and (6)
attributable to nonrequesting spouse. Rev. Proc. 2000-15, sec.
4.03(2), 2000-1 C.B. at 449, provides that the following factors
weigh against the Commissioner’s granting equitable relief: (1)
Attributable to requesting spouse, (2) knowledge, or reason to
know, (3) significant benefit, (4) lack of economic hardship, (5)
noncompliance with Federal income tax laws, and (6) requesting
spouse’s legal obligation. Further, Rev. Proc. 2000-15, supra,
provides that no single factor will be determinative, but that
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