Cynthia K. Beatty - Page 27




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          inequitable to hold the requesting spouse liable for such liabil-           
          ity.                                                                        
               Where, as here, the requesting spouse satisfies the thresh-            
          old conditions, section 4.02(1) of Revenue Procedure 2003-61 sets           
          forth the circumstances under which respondent ordinarily will              
          grant relief to that spouse under section 6015(f) in a case, like           
          the instant case, where a liability is reported in a joint return           
          but not paid.  Petitioner concedes that she does not qualify for            
          relief under section 4.02(1) of Revenue Procedure 2003-61.                  
          Instead, she relies on section 4.03 of that revenue procedure in            
          support of her claim for relief under section 6015(f).                      
          Section 4.03 of Revenue Procedure 2003-61 provides a list of                
          factors which respondent is to take into account in considering             
          whether to grant an individual relief under section 6015(f).  No            
          single factor is to be determinative in any particular case; all            
          factors are to be considered and weighed appropriately; and the             
          list of factors is not intended to be exhaustive.  Rev. Proc.               
          2003-61, sec. 4.03, 2003-2 C.B. at 298.                                     
               As pertinent here, section 4.03(2)(a) of Revenue Procedure             
          2003-61 sets forth the following factors which are to be consid-            
          ered and weighed appropriately:                                             
                    (i) Marital status.  Whether the requesting spouse                
               is separated (whether legally separated or living                      
               apart) or divorced from the nonrequesting spouse. * * *                
                    (ii) Economic hardship.  Whether the requesting                   
               spouse would suffer economic hardship (within the                      






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