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Based on the facts and circumstances in this case, many of
the factors in Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448,
are neutral. The negative factors discussed above outweigh the
positive factors in favor of relief. Petitioner has not shown
that he will suffer economic hardship if relief is denied.
Petitioner had constructive knowledge that the liability would
not be paid for 1996 and had actual knowledge that it was not
paid in 1997. The liability for each year is attributed solely
to him because he is the spouse who earned the income in each
year.
We have considered the arguments of the parties not
specifically addressed in this opinion. They are either without
merit or irrelevant to our decision. We hold that it was not an
abuse of discretion to deny petitioner’s claim for equitable
relief under section 6015(f).
Decision will be entered
for respondent.
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