- 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’sPage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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