Cynthia K. Beatty - Page 28




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               meaning of section 4.02(1)(c) of this revenue proce-                   
               dure) if the Service does not grant relief from the                    
               income tax liability.                                                  
                    (iii) Knowledge or reason to know.                                
                    (A) Underpayment cases.  In the case of an income                 
               tax liability that was properly reported but not paid,                 
               whether the requesting spouse did not know and had no                  
               reason to know that the nonrequesting spouse would not                 
               pay the income tax liability.                                          
                  *       *       *       *       *       *       *                   
                    (C) Reason to know.  For purposes of (A) * * *                    
               above, in determining whether the requesting spouse had                
               reason to know, the Service will consider the request-                 
               ing spouse’s level of education, any deceit or evasive-                
               ness of the nonrequesting spouse, the requesting                       
               spouse’s degree of involvement in the activity generat-                
               ing the income tax liability, the requesting spouse’s                  
               involvement in business and household financial mat-                   
               ters, the requesting spouse’s business or financial                    
               expertise, and any lavish or unusual expenditures                      
               compared with past spending levels.                                    
                    (iv) Nonrequesting spouse’s legal obligation.                     
               Whether the nonrequesting spouse has a legal obligation                
               to pay the outstanding income tax liability pursuant to                
               a divorce decree or agreement. * * *                                   
                    (v) Significant Benefit.  Whether the requesting                  
               spouse received significant benefit (beyond normal                     
               support) from the unpaid income tax liability or item                  
               giving rise to the deficiency.  See Treas. Reg.                        
               §1.6015-2(d).                                                          
                    (vi) Compliance with income tax laws.  Whether the                
               requesting spouse has made a good faith effort to                      
               comply with income tax laws in the taxable years fol-                  
               lowing the taxable year or years to which the request                  
               for relief relates.                                                    
          (We shall hereinafter refer to the factors set forth in section             
          4.03(2)(a)(i), (ii), (iii), (iv), (v), and (vi) of Revenue                  
          Procedure 2003-61 as the marital status factor, the economic                






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