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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,
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