Connie J. Meadows - Page 6

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        The requesting spouse bears the burden of proving that there was              
        an abuse of discretion.  Cheshire v. Commissioner, 115 T.C. 183,              
        198 (2000), affd. 282 F.3d 326 (5th Cir. 2002); Abelein v.                    
        Commissioner, T.C. Memo. 2004-274.                                            
             As directed by section 6015(f), the Commissioner has                     
        prescribed guidelines in Rev. Proc. 2003-61, 2003-2 C.B. 296,                 
        modifying Rev. Proc. 2000-15, 2000-1 C.B. 447, that are to be used            
        in determining whether it is inequitable to hold a requesting                 
        spouse liable for all or part of the liability for any unpaid tax             
        or deficiency.  Respondent, in denying relief to petitioner,                  
        applied guidelines found in Rev. Proc. 2000-15, supra, which we               
        will refer to as the superseded guidelines.  The superseded                   
        guidelines were modified by guidelines found in Rev. Proc. 2003-              
        61, supra, which we will refer to as the applicable guidelines.               
        The applicable guidelines are effective as to requests for relief             
        filed on or after November 1, 2003, and for requests for relief               
        pending on November 1, 2003, as to which no preliminary                       
        determination letter had been issued as of that date.  Rev. Proc.             
        2003-61, sec. 7, 2003-2 C.B. at 299.  Petitioner’s application for            
        relief was filed after November 1, 2003, on August 5, 2004.                   
        Respondent’s determination letter was issued on November 10, 2005.            
             According to section 4.01 in both sets of guidelines, the                
        requesting spouse must satisfy seven conditions (threshold                    
        conditions) before the Commissioner will consider a request for               






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