- 10 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007