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v. Noncompliance With Federal Income Tax Laws
Cipriotti concluded that petitioner was in compliance with
tax laws for all of the taxable years after the subject years.
Because Rev. Proc. 2000-15, supra, states that this factor will
only serve to weigh against granting relief when it is met, and
fails to state that this factor will weigh in favor of granting
relief when it is not met, we consider this factor neutral.
vi. Requesting Spouse’s Legal Obligation
With respect to the positive counterpart of this factor, we
held that that factor does not weigh in favor of granting
equitable relief to petitioner for any of the subject years and
that it is neutral. On the record before us, we also find that
this factor is neutral in that petitioner does not have a legal
obligation pursuant to a divorce decree or agreement to pay the
liabilities in issue and has been married to Albin at all
relevant times.
c. Other Relevant Factors
On the record before us, we find that petitioner has failed
to carry her burden of establishing with respect to the subject
years any other factor that is not set forth in Rev. Proc.
2000-15, supra, and that would weigh in favor of granting her
equitable relief.
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