- 17 - 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 spouse. (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 deficiencyPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011