- 6 -
(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
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: March 27, 2008