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(c) Significant benefit. The requesting
spouse has significantly benefitted (beyond normal
support) from the unpaid liability * * * [the
significant benefit negative factor].
(d) Lack of economic hardship. The
requesting spouse will not experience economic
hardship (within the meaning of section 4.02(1)(c)
of this revenue procedure) if relief from the
liability is not granted [the lack of economic
hardship negative factor].
(e) Noncompliance with federal income laws.
The requesting spouse has not made a good faith
effort to comply with federal income tax laws in
the tax years following the tax year or years to
which the request for relief relates [the tax law
noncompliance negative factor].
(f) Requesting spouse’s legal obligation.
The requesting spouse has a legal obligation
pursuant to a divorce decree or agreement to pay
the liability [the requesting spouse’s legal
obligation negative factor]. [Rev. Proc. 2000-15,
sec. 4.03.]
Regarding the liability attribution negative factor,
petitioner contends that the majority of the unpaid liability is
attributable to Mr. George. In a letter to respondent dated July
27, 2001, petitioner’s representative stated that the aggregate
tax liability for the 6 years at issue should be allocated as
follows:
Mr. George Petitioner Combined
Tax $38,819 $13,382 $52,201
Pen./Int. 30,761 12,127 42,888
Total 69,580 25,509 95,089
Petitioner further contends that, if she had filed separate
rather than joint returns, her unpaid liability would total only
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