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(f) Requesting spouse’s legal obligation. The
requesting spouse has a legal obligation pursuant to a
divorce decree or agreement to pay the liability.
As previously discussed in detail in this opinion, we have
found that both petitioner and Mr. Barnes were investors in the
partnership, and we have accordingly found that the deficiencies
are attributable equally to petitioner and Mr. Barnes. In
reviewing respondent’s denial of section 6015(f) relief with
respect to the portions of the deficiencies attributable to
petitioner, we find petitioner’s personal involvement as an
investor to be a significant factor. Another significant factor
weighing against relief is that petitioner had reason to know of
the understatements, as discussed above in connection with the
application of section 6015(b).
There is no evidence that petitioner was abused by Mr.
Barnes, or that petitioner was to any degree coerced into
becoming an investor--even if petitioner went along with the
investment in order to avoid conflict with Mr. Barnes or his
family, she nevertheless became an investor voluntarily.
Petitioner’s arguments to the contrary are not supported by the
record and are even contradicted by petitioner’s own testimony.
Finally, because petitioner has not shown that she would be
unable to pay her reasonable basic living expenses, especially in
light of the substantial continuing income that she and Mr.
Edwards receive, petitioner has not shown that she would suffer
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