- 24 - 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, itsPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011