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denied. See sec. 301.6343-1(b)(4)(i), Proced. & Admin. Regs.
Petitioner did not provide the requested Form 433-A to the
Appeals officer, but at trial she provided a monthly financial
statement that she had prepared herself. Her financial statement
reflects that after paying all of her expenses, she would have
money left over at the end of the month. We therefore conclude
that petitioner does not qualify for relief under Rev. Proc.
2003-61, sec. 4.02.
C. Factors for Determining Whether To Grant Equitable
Relief
Where the requesting spouse satisfies the seven threshold
conditions set forth in Rev. Proc. 2003-61, sec. 4.01, but does
not qualify for relief under Rev. Proc. 2003-61, sec. 4.02, he or
she may still be granted relief if, upon taking into account all
the facts and circumstances, it would be inequitable to hold the
requesting spouse liable for all or part of the unpaid
deficiency. Rev. Proc. 2003-61, sec. 4.03, 2003-2 C.B. at 298.
Rev. Proc. 2003-61, sec. 4.03(2) sets forth a nonexclusive list
of factors that the Commissioner will consider in determining
whether, taking into account all the facts and circumstances, it
is inequitable to hold the requesting spouse liable for all or
part of the liability. No single factor will determine whether
equitable relief will be granted in any particular case, and the
Commissioner will consider and weigh all relevant factors,
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