- 18 - respondent’s contentions. We now address each of these factors separately. 1. Requesting Spouse’s Legal Obligation Factor Petitioner’s divorce decree does not place the legal obligation to pay the unpaid 1989 tax liability on either petitioner or her former husband. Respondent contends that the fact that Mr. Washington does not have a legal obligation under the divorce decree to pay the unpaid 1989 tax liability weighs against granting relief to petitioner. Respondent’s contention is flawed. Section 4.03(1)(e) of Rev. Proc. 2000-15, 2000-1 C.B. at 449, indicates that if Mr. Washington had a legal obligation under the divorce decree to pay the 1989 tax liability, then that fact would weigh in favor of granting relief to petitioner; likewise, if the divorce decree had placed the obligation to pay the tax on petitioner, then that fact would weigh against granting relief to petitioner as indicated in section 4.03(2)(f) of Rev. Proc. 2000- 15, 2000-1 C.B. at 449. But here, the divorce decree did not establish whose (petitioner’s or Mr. Washington’s) obligation it was to pay the unpaid 1989 tax liability. Therefore, this is a neutral factor. 2. Abuse Factor Petitioner does not assert that she was abused by Mr. Washington or otherwise coerced into executing the 1989 joint return. However, in response to questioning by respondent’sPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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