- 12 - supra; Ferrarese v. Commissioner, supra; Foley v. Commissioner, supra; Robinson v. Commissioner, supra; Klimenko v. Commissioner, supra; Hillman v. Commissioner, supra. 4. Compliance With Tax Laws Petitioner complied with Federal income tax laws after 1996, the last of the years to which petitioner’s request for relief relates. This factor is neutral. 5. Economic Hardship Respondent determined and contends that petitioner would not suffer economic hardship if relief were not granted. We disagree. a. Background A factor treated by the Commissioner as weighing in favor of relief under section 6015(f) is that paying the taxes owed would cause the requesting spouse to suffer economic hardship. Rev. Proc. 2000-15, sec. 4.03(1)(b), 2000-1 C.B. at 448. Respondent considers the taxpayer to suffer economic hardship if paying the tax would prevent the taxpayer from paying reasonable basic living expenses. Sec. 301.6343-1(b)(4)(i), Proced. & Admin. Regs.; Rev. Proc. 2000-15, secs. 4.02(1)(c) and 4.03(1)(b), 2000- 1 C.B. at 448-449. The Commissioner considers any information provided by the taxpayer in determining a reasonable amount for basic living expenses, including the following: (1) The taxpayer’s age,Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011