Susan L. Abelein - Page 43

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          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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