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liabilities from which she seeks relief would result in economic
hardship within the meaning of section 301.6343-1(b)(4), Proced.
& Admin. Regs. Because petitioner has failed to establish that
she will suffer economic hardship, we conclude that this factor
does not weigh in favor of granting her relief.
The fact that petitioner has failed to establish that she
will suffer economic hardship, however, does not necessarily
establish that she will not suffer economic hardship. It is not
clear from the record that petitioner will not suffer economic
hardship if she is not relieved of her liability to pay the tax.
Consequently, this factor does not weigh against granting
petitioner relief. Economic hardship is a neutral factor in this
case.
3. Abuse by Nonrequesting Spouse
Petitioner was not abused by Mr. Sturges, and she does not
assert that Mr. Sturges coerced her into executing the 2000 joint
return. This factor does not weigh in favor of granting relief
to petitioner. See Ewing v. Commissioner, 122 T.C. at 46;
Washington v. Commissioner, 120 T.C. 137, 149 (2003).
4. Requesting Spouse’s or Nonrequesting Spouse’s Legal
Obligation
Because petitioner and Mr. Sturges are not separated or
divorced, this factor does not weigh in favor of or against
granting relief to petitioner. See Abelein v. Commissioner, T.C.
Memo. 2004-274.
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