- 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