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evidence of her current financial condition, we conclude that
requiring petitioner to pay the liabilities allocated to her
under section 6015(c) would not result in economic hardship as
that term is defined under Rev. Proc. 2000-15. Consequently,
this factor applies and weighs against granting petitioner
equitable relief in our analysis.
e. Noncompliance With Federal Income Tax Laws in
Subsequent Years
Respondent did not determine that this factor applies and
weighs against granting petitioner equitable relief. Moreover,
respondent does not argue in his posttrial briefs that petitioner
did not make a good faith effort to comply with her Federal
income tax obligations in years subsequent to the ones at issue
here. Consequently, we conclude that this factor does not apply,
and we treat it as neutral in our analysis.
f. Requesting Spouse’s Legal Obligation
With respect to the positive counterpart of this factor, we
concluded that petitioner and Mr. Capehart were married during
all relevant times, that they were not divorced when Mr. Capehart
died, and that neither petitioner nor Mr. Capehart had assumed
sole responsibility to pay the liabilities at issue in this case.
These conclusions also dictate our treatment of this factor.
Because petitioner was not solely responsible for paying the
liabilities at issue in this case, this factor does not apply,
and we treat it as neutral in our analysis.
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