Emily Velez - Page 10




                                        - 9 -                                         
          296, modifying and superseding Rev. Proc. 2000-15, 2000-1 C.B.              
          447.                                                                        
               Rev. Proc. 2003-61, sec. 4.01, 2003-2 C.B. at 297, begins              
          with a list of seven threshold conditions that a taxpayer must              
          satisfy in order to qualify for relief under section 6015(f).               
          Respondent concedes that petitioner satisfies each of the seven             
          threshold conditions.                                                       
               A requesting spouse who satisfies all of the applicable                
          threshold conditions may be relieved of all or part of the                  
          liability under section 6015(f), if, taking into account all the            
          facts and circumstances, the IRS determines that it would be                
          inequitable to hold the requesting spouse liable for the income             
          tax liability.  Rev. Proc. 2003-61, sec. 4.01.                              
               To qualify for relief under Rev. Proc. 2003-61, sec. 4.02,             
          2003-2 C.B. at 298, the requesting spouse must:  (1) No longer be           
          married to, be legally separated from, or not have been a member            
          of the same household as the nonelecting spouse at any time                 
          during the 12-month period ending on the date of the request for            
          relief;  (2) have had no knowledge or reason to know when he or             
          she signed the return that the nonelecting spouse would not pay             
          the tax liability; and (3) suffer economic hardship if relief is            
          not granted.  See Rev. Proc. 2003-61, sec. 4.02(1), 2003-2 C.B.             
          at 298.                                                                     








Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next 

Last modified: March 27, 2008