- 29 -
(2d Cir. 1993), affg. T.C. Memo. 1992-228; Alt v. Commissioner,
119 T.C. 306, 314 (2002); Jonson v. Commissioner, 118 T.C. at
119. It is also relevant to petitioner’s claim for relief that
petitioner and Mr. Wiwi were married for less than 4 months in
1995; all of the problems began with Mr. Wiwi in that most of Mr.
Wiwi’s underpayment of tax for 1995 apparently occurred because
he failed to make estimated tax payments before they were
married. These facts support petitioner’s claim that she is
entitled to relief under section 6015(f).
10. Conclusion
Petitioner has presented an especially strong case for
relief from joint liability under factors promulgated by the
Commissioner in Rev. Proc. 2000-15, supra: all of these factors
either weigh in favor of petitioner or are neutral, and none of
those factors weigh against granting relief to petitioner.
Petitioner did not significantly benefit from the underpayment,
the underpayment was solely attributable to Mr. Wiwi, she has
complied with Federal tax laws at least since 1995, she did not
know or have reason to know Mr. Wiwi would not pay the unpaid tax
for 1995, and payment of the tax would cause economic hardship.
The neutral factors include petitioner’s marital status and lack
of spousal abuse. The legal obligation factor does not apply
here because petitioner and Mr. Wiwi are still married. We
determine that respondent’s denial of relief under section
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