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found in Rev. Proc. 2003-61, 2003-2 C.B. 296. We review
respondent’s denial of relief under section 6015(f) for abuse of
discretion. See Alt v. Commissioner, 119 T.C. at 315-316.
Rev. Proc. 2003-61, sec. 4.01, 2003-2 C.B. at 297, provides
seven threshold conditions to determine relief. Respondent
concedes that Mrs. Dunne satisfies these conditions. Mrs. Dunne
mistakenly argues that she is entitled to relief by satisfying
these threshold conditions alone. On the contrary, after a
taxpayer satisfies the threshold requirements, Rev. Proc. 2003-
61, sec. 4.03, 2003-2 C.B. at 298, provides the Commissioner a
nonexclusive list of factors that the Commissioner uses in
determining whether the individual is entitled to relief on the
basis of all the facts and circumstances in the case. The
relevant factors to be considered here are marital status,
economic hardship, knowledge or reason to know, significant
benefit, and compliance with the income tax laws.
The fact that petitioners have been married and living
together at all relevant times is neutral.
The economic hardship factor also weighs against Mrs. Dunne.
Mrs. Dunne’s only argument regarding this factor is that the
amount of tax due is large. However, Mrs. Dunne has not provided
any evidence that (1) she will suffer economic hardship if we do
not grant her relief, (2) she does not have sufficient assets to
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