- 28 - 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 economicPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 NextLast modified: November 10, 2007