Deborah Ann Puckett - Page 12

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          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.                          









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