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Petitioner has not established that she did not know, or had
no reason to know, that the reported tax liabilities on the 1988
and 1989 joint tax returns would be unpaid at the time she signed
those joint tax returns. See Rev. Proc. 2000-15, sec.
4.03(1)(d), 2000-1 C.B. at 449. Petitioner has not established
that she will suffer economic hardship if relief is not granted.
On the record before us, petitioner has not demonstrated that
respondent’s failure to grant equitable relief for the unpaid
1988 and 1989 joint tax liabilities was an abuse of discretion.
Decision will be
entered under Rule 155.
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