Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor - Page 12

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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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