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support) from the unpaid liability; (4) the requesting spouse
will not experience economic hardship if relief is denied; (5)
the requesting spouse has not made a good-faith effort to comply
with Federal income tax laws in the tax years following the tax
year to which the request for relief relates; and (6) the
requesting spouse has a legal obligation pursuant to a divorce
decree or agreement to pay the liability. No single factor is
determinative in any particular case; all factors are to be
considered and weighed appropriately; and the list of factors is
not intended to be exhaustive. See Washington v. Commissioner,
120 T.C. at 148; Jonson v. Commissioner, 118 T.C. 106, 125
(2002).
Respondent argues that petitioner is not eligible for relief
under section 6015(f) because the negative factors in Rev. Proc.
2000-15, supra, outweigh the positive factors in that revenue
procedure. Respondent primarily relies on the following:
Petitioner will not suffer economic hardship if she is denied
relief; petitioner’s income is the sole basis for the deficiency;
and petitioner knew that her earned income was not included on
the 1998 joint return. On the basis of our review of the record
in this case, we agree with respondent.
The record is devoid of any evidence demonstrating that
petitioner will experience any economic hardship if relief from
the liability is not granted. Petitioner did not offer any proof
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