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spouse had reason to know of the items giving rise to the
increased liability and whether she significantly benefited from
the unpaid liability. See Rev. Proc. 2000-15, sec. 4.03(2)(b),
supra, 2000-1 C.B. at 449.
Mrs. Haggart failed to introduce any evidence to establish
that respondent’s denial of equitable relief was an abuse of
discretion. Additionally, we found that Mrs. Haggart had reason
to know of the disallowed deductions and omitted income.
Furthermore, it appears she would have significantly benefited
from the unpaid liabilities. As a result, we hold that Mrs.
Haggart is not eligible for relief from joint and several
liability under section 6015(f).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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