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Those procedures are found in Rev. Proc. 2000-15, 2000-1 C.B.
447.2 The revenue procedure includes a partial list of the
positive and negative factors to be considered, including whether
the requesting spouse is divorced, whether the requesting spouse
would suffer undue economic hardship, whether the requesting
spouse “had no reason to know of the items giving rise to the
deficiency”, and whether the requesting spouse significantly
benefited from the items giving rise to the deficiency. See Rev.
Proc. 2000-15, sec. 4.03(1) and (2), 2000-1 C.B. at 448-449. We
are at a loss to explain respondent’s comment that petitioner has
not shown undue economic hardship. In a Statement of
Disagreement as to respondent’s denial of innocent spouse relief
petitioner stated that she suffered from fibromyalgia and could
not work, she had to live at a friend’s house because she could
not afford her own home, her former husband is not paying alimony
as required by the divorce decree, and she did not make “ends
meet.” This statement has not been questioned by respondent. It
seems that respondent was exclusively focused on whether she knew
or had reason to know of the items that gave rise to the
deficiency. But, even if we assume that she did, “No single
factor will be determinative of whether equitable relief will or
will not be granted in any particular case. Rather all factors
2 Rev. Proc. 2000-15, sec. 3, 2000-1 C.B. 447, 448, is
applicable for any liability for tax arising on or before July
22, 1998, that was unpaid on that date.
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