Bea-Jaye Ware - Page 10




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          consider the absence of any of the factors (1), (2), (3), or (4)            
          as weighing in favor of, or against, whether to grant relief                
          under section 6015(f).  Rev. Proc. 2000-15, sec. 4.03, 2000-1               
          C.B. at 448-449.                                                            
               Rev. Proc. 2000-15, sec. 4.03, lists the following four                
          factors which, if true, the Commissioner treats as favoring                 
          relief, and which, if not true, the Commissioner treats as not              
          favoring relief:  (5) The taxpayer would suffer economic hardship           
          if relief were denied; (6) in the case of a liability that was              
          properly reported but not paid, the taxpayer did not know and had           
          no reason to know that the liability would not be paid; (7) the             
          liability for which relief is sought is attributable to the                 
          nonrequesting spouse; and (8) the nonrequesting spouse has a                
          legal obligation pursuant to a divorce decree or agreement to pay           
          the outstanding tax liability (weighs against relief only if the            
          requesting spouse has the obligation).  Rev. Proc. 2000-15, sec.            
          4.03, also states that no single factor is controlling, all                 
          factors will be considered and weighed appropriately, and the               
          list of factors in Rev. Proc. 2000-15, sec. 4, is not exhaustive.           
               1.   Petitioner’s Marital Status                                       
               Petitioner and Mr. Crouch were still married when petitioner           
          sought relief.  This factor is neutral.                                     










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Last modified: November 10, 2007