Robby Goodale Gilbert - Page 13

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          he was legally obligated to pay under the divorce decree for his            
          share of the tax liabilities for the years at issue.                        
               Petitioner’s filing for divorce prior to requesting relief             
          under section 6015(f) favors granting him relief.  Rev. Proc.               
          2000-15, sec. 4.03(1)(a).  Yet, even in those cases where the               
          requesting spouse’s marital status favors granting relief, Rev.             
          Proc. 2000-15, sec. 4.03(1)(f), 2000-1 C.B. at 449, questions               
          whether the tax liability is attributable to the spouse                     
          requesting relief.  The basis for denying petitioner relief under           
          section 6015(f) stemmed from respondent’s belief that the                   
          entirety of the tax liabilities for 2000 and 2001 arose from                
          income earned by petitioner.  Petitioner concedes his                       
          responsibility for any tax liability associated with the income             
          he earned during the years at issue from his employment with the            
          Art Institute of Seattle.  He similarly concedes that the portion           
          of the underpayment from taxable year 2000 that arose from the              
          sale of stock was solely his income.  The tax liability                     
          associated with the income earned by Ms. Peet for assisting                 
          petitioner with Interactive Arts, his wholly owned Schedule C               
          business, during the years at issue, however, is the subject of             
          petitioner’s dispute.  At trial, petitioner testified that Ms.              
          Peet performed design work for Interactive Arts, assisted in                
          administering the affairs of the business, and received income              
          from Interactive Arts for these services.  Respondent contends              

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