- 11 - agreement to pay the unpaid liability. See Rev. Proc. 2000-15, sec. 4.03(2), 2000-1 C.B. at 449. For reasons to be discussed, we conclude that petitioner does not qualify for relief under section 4.02 or 4.03 of the revenue procedure. In order to streamline our discussion, we shall focus exclusively on the factors enumerated in section 4.03 of the revenue procedure. That discussion, however, will make apparent why petitioner fails to qualify for relief under either section of the revenue procedure. A. Neutral Factors We consider many of the factors to be neutral, weighing neither in favor of nor against granting petitioner relief. 1. Abuse Petitioner was not abused by Mr. Puckett. Lack of spousal abuse is not a factor listed in Rev. Proc. 2000-15, sec. 4.03(2), 2000-1 C.B. at 449, that weighs against granting relief. Therefore, this factor is neutral. See Washington v. Commissioner, 120 T.C. 137, 149 (2003). 2. Compliance With Federal Income Tax Laws Respondent concedes that petitioner has complied with her income tax filing requirements. This factor does not weigh in favor of or against granting relief to petitioner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011