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4. Conclusion
Upon examination of the entire record before us, we find
that petitioner has failed to carry her burden of establishing
that respondent abused his discretion in denying her equitable
relief for all of the subject years. The only positive factor
that supports granting petitioner equitable relief is that the
liabilities in issue are attributable solely to Albin. Two
negative factors, i.e., reason to know and lack of economic
hardship, weigh against granting her equitable relief. As noted
above, the reason-to-know factor is “an extremely strong factor
weighing against relief” which generally may be outweighed only
“when the factors in favor of equitable relief are unusually
strong”. Rev. Proc. 2000-15, sec. 4.03(2)(b). The fact that the
subject liabilities are attributable solely to Albin is not such
an “unusually strong” factor. Id. Such is especially so given
that we do not find that petitioner will suffer an economic
hardship in paying those liabilities. We conclude and hold that
respondent did not abuse his discretion when he denied equitable
relief to petitioner as to the liabilities in issue.
All of petitioner’s arguments have been considered, and we
have rejected those arguments not discussed herein as without
merit.
Decision will be entered
for respondent.
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