According to Procedurally Taxing, Goode v. Commissioner, T.C. Summ. Op. 2021-34 finds another spouse seeking relief from liability under IRC 6015 failing because of the knowledge element and the lack of economic hardship.
In the recent post entitled “Is Economic Hardship the Antidote for Knowledge in an Innocent Spouse Case?” the Tax Court has created an unmistakable pattern of finding against spouses who have knowledge of the item giving rise to the liability and do not prove economic hardship.
The Goode Case Is Another Case Where
The Petitioner Had Three Positive Factors And
Only One Negative Factor, Knowledge.
Despite the numerical advantage of the positive factors, the knowledge factor continues to enjoy the status of a super factor, unless the taxpayer seeking relief can successfully raise the antidote of economic hardship.
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