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are several factors that are relevant to the Court's analysis,
including but not limited to: (1) The alleged innocent spouse's
level of education; (2) the spouse's involvement in the family's
business and financial affairs; and (3) the culpable spouse's
evasiveness and deceit concerning the couple's finances. Id. at
284.
Ms. Wang has a degree in engineering from Purdue University
and had full responsibility for the family finances. She had
full access to the family bank accounts, reviewed the bank
account statements monthly, and maintained and balanced the
family checkbook. Ms. Wang also prepared the tax return for the
year in issue. Finally, Mr. Applegate made no attempt to deceive
Ms. Wang about expenditures he made regarding his employment. In
fact, she admits he gave her all his receipts for the
expenditures. Ms. Wang simply made no effort to question him
about them despite the fact that his expenses of over $31,000
equaled almost 76 percent of his income of $41,400.
The Court finds that Ms. Wang has failed to satisfy the
requirements of section 6015(b)(1)(C). Therefore, she does not
qualify for relief under section 6015(b).
B. Section 6015(f)
Ms. Wang may still qualify for relief, however, under
section 6015(f). Section 6015(f) grants the Commissioner
discretion to relieve from joint and several liability an
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