Mary A. George - Page 16

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                    if relief from the liability is not granted [the                  
                    economic hardship positive factor].                               
                         (c) Abuse.  The requesting spouse was abused                 
                    by the nonrequesting spouse, but such abuse did                   
                    not amount to duress [the abuse positive factor].                 
                         (d) No knowledge or reason to know.  In the                  
                    case of a liability that was properly reported but                
                    not paid, the requesting spouse did not know and                  
                    had no reason to know that the liability would not                
                    be paid [the knowledge positive factor].                          
                         (e) Nonrequesting spouse’s legal obligation.                 
                    The nonrequesting spouse has a legal obligation                   
                    pursuant to a divorce decree or agreement to pay                  
                    the outstanding liability [the nonrequesting                      
                    spouse’s legal obligation positive factor].                       
                         (f) Attributable to nonrequesting spouse.                    
                    The liability for which relief is sought is solely                
                    attributable to the nonrequesting spouse [the                     
                    liability attribution positive factor].                           
               As to the marital status positive factor, petitioner’s                 
          marital status weighs in favor of relief because Mr. George was             
          deceased at the time petitioner sought equitable relief.  The               
          economic hardship positive factor does not weigh in favor of                
          relief.  As stated above, we do not believe that petitioner would           
          suffer economic hardship if relief from the tax liabilities were            
          not granted.  The abuse positive factor does not weigh in favor             
          of relief.  On her Form 886-A, petitioner conceded that marital             
          abuse does not apply.                                                       
               The knowledge positive factor does not weigh in favor of               
          relief.  As stated above, we believe that petitioner knew or had            








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