Gwendolyn A. Ewing - Page 29

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          (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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