Ann Marie Bright - Page 15

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          sec. 4.03(2), 2000-1 C.B. at 449, lists the following six factors           
          weighing against granting relief for an unpaid liability:  (1)              
          The unpaid liability is attributable to the requesting spouse;              
          (2) the requesting spouse knew or had reason to know at the time            
          the return was signed that the reported liability would be                  
          unpaid; (3) the requesting spouse significantly benefited (beyond           
          normal support) from the unpaid liability; (4) the requesting               
          spouse will not suffer economic hardship if relief is denied;               
          (5) the requesting spouse has not made a good faith effort to               
          comply with Federal income tax laws in the tax years following              
          the tax year to which the request for relief relates; and (6) the           
          requesting spouse has a legal obligation pursuant to a divorce              
          decree or agreement to pay the unpaid liability.  This list is              
          not exhaustive, no single factor is determinative, and all                  
          factors should be considered and weighed appropriately.  Rev.               
          Proc. 2000-15, sec. 4.03.                                                   
               As we view the matter, the factors in favor of granting                
          petitioner relief outweigh the factors against granting                     
          petitioner relief.  Petitioner is divorced from her former                  
          spouse.  Respondent concedes that petitioner was abused by                  
          her former spouse during the marriage.  As discussed above,                 
          petitioner did not know or have reason to know that the reported            
          1995 tax liability would not be paid by her former spouse.                  








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