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C. Application of the Factors Listed in Rev. Proc. 2000-15
1. Petitioner’s Marital Status
Petitioner was divorced from her former husband when she
sought relief. This factor favors petitioner.
2. Spousal Abuse
Petitioner did not allege that there was abuse in her former
marriage. Respondent determined that this factor is neutral.
We agree with respondent’s determination on this point.
3. Significant Benefit
Respondent found this factor favors petitioner, and we
agree.
4. Compliance With Tax Laws
This factor was considered neutral since petitioner was in
compliance.
5. Economic Hardship
Respondent determined that because petitioner had remarried,
this factor was not present. We disagree. There is no question
that apart from any support from her current husband the
liability would cause petitioner significant hardship, and
petitioner provided sufficient information to the Appeals officer
to show her liabilities significantly exceeded her assets. We
find that economic hardship is a significant favorable factor for
petitioner because payment of the underlying liabilities would
prevent petitioner from paying reasonable basic living expenses
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Last modified: November 10, 2007