- 47 - 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.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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