Phyllis J. Merendino - Page 17

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          4.02, then Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. 447, 448-             
          449, sets forth guidelines or factors that the Commissioner will            
          consider in deciding claims for equitable relief under section              
          6015(f).  Rev. Proc. 2000-15, sec. 4.03(1), 2000-1 C.B. at 448-             
          449, sets forth the following positive factors which weigh in               
          favor of granting equitable relief under section 6015(f):                   
                    (a) Marital status.  The requesting spouse is                     
               separated * * * or divorced from the nonrequesting                     
                    (b) Economic hardship.  The requesting spouse                     
               would suffer economic hardship (within the meaning of                  
               section 4.02(1)(c) of this revenue procedure) if relief                
               from the liability is not granted.                                     
                    (c) Abuse.  The requesting spouse was abused by                   
               the nonrequesting spouse, but such abuse did not amount                
               to duress.                                                             
                    (d) No knowledge or reason to know.  In the case                  
               of a liability that was properly reported but not paid,                
               the requesting spouse did not know and had no reason to                
               know that the liability would not be paid. * * *                       
                    (e) Nonrequesting spouse's legal obligation.  The                 
               nonrequesting spouse has a legal obligation pursuant to                
               a divorce decree or agreement to pay the outstanding                   
               liability. * * *                                                       
                    (f) Attributable to nonrequesting spouse.  The                    
               liability for which relief is sought is solely                         
               attributable to the nonrequesting spouse.                              
               Rev. Proc. 2000-15, sec. 4.03(2), 2000-1 C.B. at 449, sets             
          forth the following negative factors which weigh against granting           
          equitable relief under section 6015(f):                                     
                    (a) Attributable to the requesting spouse.  The                   
               unpaid liability or item giving rise to the deficiency                 

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