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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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