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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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