Jeanine T. Foor - Page 14

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          factors.  Although we do not find fault with the determination              
          that petitioner had reason to know that the reported tax                    
          liabilities would not be paid, on the basis of the particular               
          facts and circumstances involved, we find that compelling reasons           
          existed to grant equitable relief.  Petitioner is divorced, she             
          will suffer economic hardship if relief is not granted, she did             
          not significantly benefit from the unpaid taxes, and there were             
          several other factors known to respondent at the time of the                
          determination that weighed in favor of granting relief.                     
          Consequently, we hold that respondent’s denial of equitable                 
          relief was an abuse of discretion and that it would be                      
          inequitable to hold petitioner liable for the unpaid tax                    
          liabilities for the years in issue.                                         

                                                  Decision will be entered            
                                             for petitioner.                          

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