Tracie Young - Page 14

                                       - 13 -                                         
          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              







Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  Next

Last modified: May 25, 2011