Wendlyn H. Albin - Page 24

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                    iii.  Abuse                                                       
               Petitioner does not claim that this factor favors her                  
          position.  Nor do we find that such is the case.  The record does           
          not establish that petitioner was abused by Albin in any regard.            
          We hold that this factor does not weigh in favor of granting                
          equitable relief to petitioner for any of the subject years.                
          Because Rev. Proc. 2000-15, supra, states that this factor will             
          only serve to weigh in favor of granting relief when it is met,             
          and fails to state that this factor will weigh against granting             
          relief when it is not met, we consider this factor neutral.                 
                         iv.  No Knowledge or Reason To Know                          
               Petitioner’s liabilities in issue arose from deficiencies.             
          Petitioner argues that she did not know and had no reason to know           
          of the items giving rise to those deficiencies.  As mentioned               
          above, respondent makes no claim that petitioner actually knew              
          about the understatement or the shelter and deductions related              
          thereto.                                                                    
               The parties do not dispute that the facts and circumstances            
          that the Court must consider in determining whether petitioner              
          has established that this factor is present are the same facts              
          and circumstances that the Court must consider in determining               
          that petitioner did not satisfy section 6015(b)(1)(C).  Indeed,             
          in holding that a requesting spouse did not qualify for equitable           
          relief, the Court has previously relied on, inter alia, its                 






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