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requesting spouses, who were living at or near poverty level at
the time of their request and who proved that they would suffer
economic hardship without relief from joint and several
liability. See, e.g., Washington v. Commissioner, 120 T.C. 137
(2003); cf. Collier v. Commissioner, T.C. Memo. 2002-144. On the
record in this case, petitioner has failed to show that
respondent’s determination regarding economic hardship was an
abuse of discretion.
Attribution to Nonrequesting Spouse
Under Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448,
section 6015(f) relief will ordinarily be granted where the
requesting spouse is no longer married to the nonrequesting
spouse; the requesting spouse would suffer economic hardship; and
the requesting spouse, at the time the return was signed, had no
knowledge or reason to know that the tax would not be paid.
Relief is limited to the extent that the unpaid liability is
allocable to the nonrequesting spouse. In addition, one of the
positive factors in Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at
448, weighing in favor of relief is that the liability is
attributable solely to the nonrequesting spouse.
Petitioner concedes that he earned the income that gave rise
to the liabilities from which he now seeks relief. Petitioner
claims, however, that the unpaid liability is attributable to
Ms. Trevino because she was responsible for the family finances
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