Floyd William Munsinger & Audreanne Elise Lewallen, f.k.a. Audreanne Elise Munsinger - Page 10




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         i.e., Mr. Munsinger, unless one of the enumerated exceptions                 
         applies, which none do.                                                      
              As to the omitted wage income attributable to Mr. Munsinger,            
         Ms. Lewallen does satisfy the seven threshold conditions.  The               
         inquiry then turns to whether any circumstances are present under            
         which relief would normally be granted.  See id., sec. 4.02,                 
         2003-2 C.B. at 298.  Ms. Lewallen testified at trial that she                
         would not suffer economic hardship if relief were not granted,               
         and no special circumstances are present in this case.                       
              Consequently, we must examine whether, taking into account              
         all the facts and circumstances, it is inequitable to hold Ms.               
         Lewallen liable for all or part of the deficiency stemming from              
         the omission of Mr. Munsinger’s wage income.  See id., sec. 4.03,            
         2003-2 C.B. at 298.  We hold that it is not.                                 
              Petitioners’ divorce decree is silent on the allocation of              
         outstanding Federal tax debts, and, as noted above, Ms. Lewallen             
         would not suffer economic hardship if relief were not granted.               
         Most importantly, however, Rev. Proc. 2003-61, sec. 4.03,                    
         specifically states that actual knowledge by the requesting                  
         spouse of the item giving rise to the deficiency is a strong                 
         factor weighing against relief and may be overcome only if the               
         factors in favor of equitable relief are particularly compelling.            
         Unfortunately for Ms. Lewallen, no compelling factors present                








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