- 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 thatPage: 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