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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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