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(c) Abuse. The requesting spouse was abused by
the nonrequesting spouse, but such abuse did not amount
to duress.
(d) No knowledge or reason to know. In the case
of a liability that was properly reported but not paid,
the requesting spouse did not know and had no reason to
know that the liability would not be paid. In the case
of a liability that arose from a deficiency, the
requesting spouse did not know and had no reason to
know of the items giving rise to the deficiency.
(e) Nonrequesting spouse’s legal obligation. The
nonrequesting spouse has a legal obligation pursuant to
a divorce decree or agreement to pay the outstanding
liability. This will not be a factor weighing in favor
of relief if the requesting spouse knew or had reason
to know, at the time the divorce decree or agreement
was entered into, that the nonrequesting spouse would
not pay the liability.
(f) Attributable to nonrequesting spouse. The
liability for which relief is sought is solely
attributable to the nonrequesting spouse.
Rev. Proc. 2000-15, sec. 4.03(2), 2000-1 C.B. at 449, lists the
following six negative factors which weigh against granting
equitable relief:
(a) Attributable to the requesting spouse. The
unpaid liability or item giving rise to the deficiency
is attributable to the requesting spouse.
(b) Knowledge, or reason to know. A requesting
spouse knew or had reason to know of the item giving
rise to a deficiency or that the reported liability
would be unpaid at the time the return was signed.
This is an extremely strong factor weighing against
relief. Nonetheless, when the factors in favor of
equitable relief are unusually strong, it may be
appropriate to grant relief under � 6015(f) in limited
situations where a requesting spouse knew or had reason
to know that the liability would not be paid, and in
very limited situations where the requesting spouse
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