Angela C. Morris - Page 9




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          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.                                              










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