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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’s
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