Linda D. Farmer - Page 8




                                        - 8 -                                         
          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             







Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next 

Last modified: November 10, 2007