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In accordance with the above, we shall consider each of the
positive and negative factors enumerated in Rev. Proc. 2000-15,
sec. 4.03. We shall also consider whether any additional facts
alleged by the parties affect the analysis of whether respondent
abused his discretion in denying petitioner equitable relief
under section 6015(f).
1. Positive Factors
a. Marital Status
Petitioner is still married and living with Mr. Abelein.
Consequently, this positive factor does not apply. Ewing v.
Commissioner, supra at 46.
b. Economic Hardship
An analysis of economic hardship under Rev. Proc. 2000-15,
supra, is conducted using rules similar to those under section
301.6343-1(b)(4), Proced. & Admin. Regs., and focuses on the
requesting spouse’s inability to pay reasonable basic living
expenses. Rev. Proc. 2000-15, sec. 4.02(1)(c). Section
301.6343-1(b)(4)(ii), Proced. & Admin. Regs., provides that the
Commissioner will evaluate a requesting spouse’s claim of
economic hardship by considering any information offered by the
requesting spouse that is relevant to the determination,
including, but not limited to, the requesting spouse’s income,
assets and liabilities, age, ability to earn, responsibility for
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