- 21 - lack of significant benefit weighed in favor of relief under Rev. Proc. 2003-61); cf. Butner v. Commissioner, supra (stating that lack of significant benefit weighed in favor of relief under former section 6013(e) notwithstanding that Rev. Proc. 2000-15 stated that it was neutral); Ferrarese v. Commissioner, T.C. Memo. 2002-249. Compliance With Federal Tax Laws The IRS will take into consideration whether the requesting spouse has made a good faith effort to comply with the Federal tax laws in the succeeding years. See Rev. Proc. 2003-61, sec. 4.03(2)(a)(vi), 2003-2 C.B. at 299. Respondent agrees that petitioner has complied with the Federal tax laws since her husband’s death. Therefore, this factor weighs in favor of relief. See Fox v. Commissioner, supra (stating that noncompliance weighs against relief under Rev. Proc. 2003-61); see also Beatty v. Commissioner, supra (stating that one delinquently filed return, which showed a refund due, and the other facts and circumstances were not significant factors weighing against relief in that case, and the Commissioner argued that the compliance factor weighed in favor of relief under Rev. Proc. 2003-61); cf. Butner v. Commissioner, supra (stating that noncompliance weighs against relief under Rev. Proc. 2000-15).Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: March 27, 2008