- 60 - Mr. Krasner. We find that respondent concedes that the attribu- tion positive factor is present here. Turning to the negative factors weighing against granting relief under section 6015(f) set forth in section 4.03(2) of Revenue Procedure 2000-15, as pertinent here, those factors are: (a) Attributable to the requesting spouse. The unpaid liability * * * is attributable to the request- ing spouse. (b) Knowledge, or reason to know. A requesting spouse knew or had reason to know * * * that the re- ported liability would be unpaid at the time the return was signed. This is an extremely strong factor weigh- ing against relief. Nonetheless, when the factors in favor of equitable relief are unusually strong, it may be appropriate to grant relief under � 6015(f) in limited situations where a requesting spouse knew or had reason to know that the liability would not be paid * * *. (c) Significant benefit. The requesting spouse has significantly benefitted (beyond normal support) from the unpaid liability * * *. (d) Lack of economic hardship. The requesting spouse will not experience economic hardship (within the meaning of section 4.02(1)(c) of this revenue procedure) if relief from liability is not granted. (e) Noncompliance with federal income tax laws. The requesting spouse has not made a good faith effort to comply with federal income tax laws in the tax years following the tax year or years to which the request for relief relates. (f) Requesting spouse’s legal obligation. The requesting spouse has a legal obligation pursuant to a divorce decree or agreement to pay the liability. (We shall hereinafter refer to the negative factors set forth in section 4.03(2)(a), (b), (c), (d), (e), and (f) of RevenuePage: Previous 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 Next
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