- 9 - v. Commissioner, T.C. Memo 2001-198. Here, we review respondent’s denial of equitable relief under section 66(c) for abuse of discretion. Id.; see also Fernandez v. Commissioner, 114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000). Pursuant to the directions in the statute, respondent issued Rev. Proc. 2000-15, 2000-5 I.R.B. 447, setting forth the criteria under which respondent will consider equitable relief. This list of factors is not intended to be exhaustive and includes consideration of the economic hardship on the spouse and whether the spouse had reason to know of the items giving rise to the deficiency. Certainly these factors are important. Petitioner knew that her husband was engaged in business, and it is petitioner’s share of that community income that gives rise to the remaining deficiency for 1996. See Beck v. Commissioner, supra. Moreover, it would appear that petitioner did benefit from that income. Finally, according to our rough calculation, the remaining deficiency is less than $200. Petitioner has not established that payment of such an amount would create a substantial hardship. Under these circumstances, we believe respondent’s denial of equitable relief to petitioner under section 66(c) was not an abuse of discretion as it relates to the remaining deficiency for 1996.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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