Judith A. Madden - Page 11

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              As directed by section 6015(f), the Commissioner has                    
         prescribed guidelines in Rev. Proc. 2000-15, 2000-1 C.B. 447,                
         that are to be used in determining whether it would be                       
         inequitable to hold a requesting spouse liable for all or part of            
         the liability for any unpaid tax or deficiency.  The requesting              
         spouse must satisfy seven conditions (threshold conditions)                  
         before the Commissioner will consider a request for relief under             
         section 6015(f).  Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at              
         448.  Respondent agrees that in this case those threshold                    
         conditions are satisfied.                                                    
              Where, as here, the requesting spouse satisfies the                     
         threshold conditions, Rev. Proc. 2000-15, sec. 4.02(1), 2000-1               
         C.B. at 448, sets forth the circumstances under which relief                 
         under section 6015(f) will ordinarily be granted in a case where             
         a liability is reported in a joint return but not paid.  Relief              
         under section 6015(f) will be granted for an unpaid tax liability            
         reported on a joint return if all of the following elements are              
                   (a) At the time relief is requested, the                           
              requesting spouse is no longer married to, or is                        
              legally separated from, the nonrequesting spouse * * *;                 
                   (b) At the time the return was signed, the                         
              requesting spouse had no knowledge or reason to know                    
              that the tax would not be paid. * * *; and                              
                   (c) The requesting spouse will suffer economic                     
              hardship if relief is not granted. * * *                                

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