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(a) Attributable to the requesting spouse. The unpaid
liability * * * is attributable to the requesting spouse.
(b) Knowledge, or reason to know. A requesting spouse
knew or had reason to know * * * that the reported liability
would be unpaid at the time the return was signed. This is
an extremely strong factor weighing against relief. * * *
(c) Significant benefit. The requesting spouse has
significantly benefitted (beyond normal support) from the
unpaid liability * * *.
(d) Lack of economic hardship. The requesting spouse
will not experience economic hardship (within the meaning of
section 4.02(1)(c) of this revenue procedure) if relief from
the liability is not granted.
(e) Noncompliance with federal income tax laws. The
requesting spouse has not made a good faith effort to comply
with federal income tax laws in the tax years following the
tax year or years to which the request for relief relates.
(f) Requesting spouse’s legal obligation. The
requesting spouse has a legal obligation pursuant to a
divorce decree or agreement to pay the liability.
In deciding whether respondent’s determination that petitioner is
not entitled to relief under section 6015(f) was an abuse of
discretion, the Court considers evidence relating to all the
facts and circumstances. Washington v. Commissioner, supra.
On this record, the Court finds that the facts and
circumstances weigh against granting relief to petitioner for the
year 1987. Most importantly, petitioner knew or had reason to
know, at the time the return was signed in 1993, that the
liability reported for 1987 would be unpaid. Butler v.
Commissioner, 114 T.C. 276 (2000). Petitioner and Mr. Barber
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