Stacy Lee Gonce - Page 11




                                       - 11 -                                         
               (ii) whether the requesting spouse would 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 the 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 the 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 Mr. Gonce, the                     
         nonrequesting spouse, several of the other Rev. Proc. 2003-61,               
         sec. 4.03, factors weigh against granting petitioner relief from             
         joint and several liability.  We have already concluded that,                
         even taking into account her medical bills, petitioner would not             
         suffer economic hardship if relief is not granted.  Petitioner               
         not only knew about Mr. Gonce’s newspaper route during the years             
         in issue, but she also maintained her own newspaper route in 1998            
         and 1999 and was familiar with the payments and procedures                   







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next 

Last modified: March 27, 2008