Janet H. Krasner, Petitioner, and Paul Krasner , Intervenor - Page 44

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          circumstances, the IRS determines that it would be inequitable to           
          hold the requesting spouse liable for such liability.                       
               Where, as here, the requesting spouse satisfies the thresh-            
          old conditions, section 4.02(1) of Revenue Procedure 2000-15 sets           
          forth the circumstances under which the IRS ordinarily will grant           
          relief to that spouse under section 6015(f) in a case, like the             
          instant case, where a liability is reported in a joint return but           
          not paid.  As pertinent here, those circumstances, which section            
          4.02 of Revenue Procedure 2000-15 and we refer to as elements,              
          are:                                                                        
                    (a) At the time relief is requested, the request-                 
               ing spouse is no longer married to, or is legally                      
               separated from, the nonrequesting spouse, or has not                   
               been a member of the same household as the                             
               nonrequesting spouse at any time during the 12-month                   
               period ending on the date relief was requested;                        
                    (b) At the time the return was signed, the re-                    
               questing spouse had no knowledge or reason to know that                
               the tax would not be paid.  The requesting spouse must                 
               establish that it was reasonable for the requesting                    
               spouse to believe that the nonrequesting spouse would                  
               pay the reported liability. * * *; and                                 
                    (c) The requesting spouse will suffer economic                    
               hardship if relief is not granted.  For purposes of                    
               this section, the determination of whether a requesting                
               spouse will suffer economic hardship will be made by                   
               the Commissioner or the Commissioner's delegate, and                   
               will be based on rules similar to those provided in                    
               � 301.6343-1(b)(4) of the Regulations on Procedure and                 
               Administration.  [Rev. Proc. 2000-15, sec. 4.02(1),                    
               2000-1 C.B. at 448.]                                                   
          (We shall hereinafter refer to the elements set forth in section            
          4.02(1)(a), (b), and (c) of Revenue Procedure 2000-15 as the                






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