- 43 -
15, 2000-1 C.B. 447. Consequently, this negative factor applies
and weighs against granting petitioner equitable relief in our
analysis.
e. Noncompliance With Federal Income Tax Laws in
Subsequent Years
Respondent did not determine that this factor applies and
weighs against granting petitioner equitable relief. Moreover,
respondent did not argue in his posttrial briefs that petitioner
did not make a good faith effort to comply with her Federal
income tax obligations in the years subsequent to the ones at
issue here. Consequently, we conclude that this negative factor
does not apply. See Ewing v. Commissioner, supra at 46-47.
f. Requesting Spouse’s Legal Obligation
With respect to the positive counterpart to this factor, we
concluded that petitioner and Mr. Abelein were married during the
relevant times and remain so and that neither petitioner nor Mr.
Abelein had assumed sole responsibility to pay the liabilities at
issue in this case. These conclusions also dictate our treatment
of this factor. Because petitioner was not solely responsible
for paying the liabilities at issue in this case, this negative
factor does not apply.
3. Other Relevant Factors
Petitioner argues that in determining whether it is
inequitable to hold petitioner liable for the deficiency, we must
consider the complexity of the transactions and Mr. Hoyt’s
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