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taxable years 1994, 1995, 1998, and 1999 of $330, $238, $1,466,
and $1,189, if she had not filed such joint returns and availed
herself of the net operating loss carryovers associated with Mr.
Butner's business enterprises; (3) petitioner also received a
significant benefit "beyond normal support, from the tax liabili-
ties that went unpaid in that money which her husband could have
used to pay estimated taxes to reduce or satisfy his
self-employment tax liability was paid to petitioner as secre-
tarial wages”; (4) petitioner would not suffer economic hardship
if the Court were not to grant relief from the liability for each
of the taxable years at issue; (5) petitioner knew or had reason
to know when she signed and filed each of the joint income tax
returns in question that the liability reported in each such
return would not be paid due to her knowledge of previous judg-
ments and assessments against Mr. Butner and herself; and (6)
petitioner failed to comply with the income tax laws for the
taxable years following the taxable years for which relief is
sought. According to respondent, the foregoing factors weigh
against granting relief under section 6015(f) to petitioner.
We now address the application of each of the factors set
forth in Revenue Procedure 2000-15 that weigh in favor of or
against granting petitioner relief under section 6015(f).
Marital Status
Respondent contends that this factor is neutral. We agree.
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