Patricia H. Devlin - Page 7




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               (i) Whether the requesting spouse is separated or divorced             
          from the nonrequesting spouse;                                              
               (ii) whether the requesting spouse will suffer economic                
          hardship if relief from the liability is not granted;                       
               (iii) whether the requesting spouse had knowledge or reason            
          to know either of the item giving rise to a tax deficiency or               
          that the nonrequesting spouse would not pay the tax liability;              
               (iv) whether the nonrequesting spouse has a legal obligation           
          pursuant to a divorce decree or agreement to pay the outstanding            
          liability;                                                                  
               (v) whether the requesting spouse has significantly                    
          benefited (beyond normal support) from the unpaid liability or              
          item giving rise to a deficiency; and                                       
               (vi) whether the requesting spouse has made a good faith               
          effort to comply with Federal income tax laws in the tax years              
          subsequent to the years to which the request for relief relates.            
          Rev. Proc. 2003-61, sec. 4.03(2)(a).                                        
              Although petitioner is divorced from Collins and has not                
         failed to comply with Federal income tax laws individually in tax            
         years subsequent to 1999, several of the other Rev. Proc. 2003-              
         61, section 4.03, factors weigh against granting her relief from             
         joint and several liability.  We have already concluded that                 
         petitioner has not shown that she will suffer economic hardship              
         if relief is not granted.  We have also concluded that petitioner            







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