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only argument against granting equitable relief is that
petitioner knew or had reason to know that the taxes would not be
paid.
When the factors in favor of equitable relief are unusually
strong, it may be appropriate to grant relief under section
6015(f) in limited situations where the requesting spouse knew or
had reason to know that the liability would not be paid.
Washington v. Commissioner, supra at 151; Rev. Proc. 2000-15,
sec. 4.03(2)(b), 2000-1 C.B. at 449. Additionally, we have
previously considered the fact that a taxpayer did not
significantly benefit from the unpaid liability as a factor in
favor of granting relief to that taxpayer. Ewing v.
Commissioner, 122 T.C. ___, ___ (2004) (slip op. at 22-23);
Ferrarese v. Commissioner, T.C. Memo. 2002-249; Rowe v.
Commissioner, T.C. Memo. 2001-325. The factors listed in Rev.
Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448-449, are not
exhaustive, and all facts and circumstances must be taken into
account in determining whether it would be inequitable to hold a
requesting spouse liable. Ewing v. Commissioner, 122 T.C. at ___
(slip op. at 28).
Petitioner presented a strong case during her dealings with
respondent and at trial for equitable relief from joint and
several liability under the factors promulgated by the
Commissioner in Rev. Proc. 2000-15, supra, and other relevant
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