Lesley J. Smith, a.k.a. Lesley J. Scott - Page 24




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               1.  Marital Status                                                     
               If the requesting spouse is separated or divorced from the             
          nonrequesting spouse, this factor would favor granting relief to            
          the requesting spouse.  Rev. Proc. 2000-15, sec. 4.03(1)(a).                
          Petitioner and Mr. Scott were divorced in January 2001.                     
          Petitioner filed her request for section 6015 relief on August 9,           
          2002.  Consequently, this factor weighs in favor of granting                
          relief to petitioner.                                                       
               2.  Economic Hardship                                                  
               If payment of the tax liability would cause the requesting             
          spouse to suffer economic hardship, this factor would support the           
          granting of equitable relief to the requesting spouse.  Id. sec.            
          4.03(1)(b).  Economic hardship occurs if payment of the                     
          liability, in whole or in part, will cause the taxpayer to be               
          unable to pay his or her reasonable basic living expenses.  Id.             
          sec. 4.02(1)(c), 2000-1 C.B. at 448; see sec.                               
          301.6343-1(b)(4)(i), Proced. & Admin. Regs.  In determining a               
          reasonable amount for basic living expenses, we consider, among             
          other things:  (1) The taxpayer’s age, employment status and                
          history, ability to earn, and number of dependents; (2) the                 
          amount reasonably necessary for food, clothing, housing, medical            
          expenses, transportation, current tax payments, alimony, child              
          support, or other court-ordered payments and expenses necessary             
          to the taxpayer’s production of income; (3) the cost of living in           







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