- 9 - 2003-61, sec. 4.03, 2003-2 C.B. at 298, contains a nonexhaustive list of factors that the IRS will consider and weigh when determining whether to grant equitable relief under section 6015(f). The factors and the Court’s analysis with respect to each factor are described below. Marital Status The IRS will take into consideration whether the requesting spouse is separated or divorced from the nonrequesting spouse. Rev. Proc. 2003-61, sec. 4.03(2)(a)(i), 2003-2 C.B. at 298. Petitioner was divorced from Mr. Nakasu when she filed her request. This factor weighs in favor of relief. See McKnight v. Commissioner, T.C. Memo. 2006-155 (stating that divorce weighs in favor of relief under Rev. Proc. 2003-61); see also Beatty v. Commissioner, T.C. Memo. 2007-167 (stating that remaining married or residing together is a neutral factor under Rev. Proc. 2003- 61); cf. Butner v. Commissioner, T.C. Memo. 2007-136 (stating same under Rev. Proc. 2000-15). Economic Hardship Petitioner contends that she is unable to pay the tax liability because she has incurred substantial credit card debt to cover their living expenses while her second husband was unemployed on account of an illness. Petitioner also testified that she pulled the equity out of her homes to cover theirPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: March 27, 2008