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findings that the requesting spouse did not satisfy section
6015(b)(1)(C). See, e.g., Butler v. Commissioner, 114 T.C. at
284-286, 292.
For the reasons discussed above in our analysis of section
6015(b)(1)(C), we conclude that petitioner had “reason to know”
of each of the understatements and shelter deductions at hand
within the meaning of this factor when she signed the subject
returns. 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
v. Nonrequesting Spouse’s Legal Obligation
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 Albin had a legal obligation pursuant to a
divorce decree or agreement to pay the outstanding liabilities.
Given the additional fact that the Albins were married to each
other at all relevant times, 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
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