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of $150,000. Petitioner could have used, but did not, these
resources to pay the liabilities. Moreover, we note that, had
Mr. George paid the joint liabilities during his lifetime, the
funds petitioner received from Mr. George at his death would have
been reduced by those payments. Consequently, petitioner
received a significant benefit beyond normal support.
The lack of economic hardship negative factor weighs against
relief. As noted above, we do not believe that petitioner will
experience economic hardship if relief is not granted.
The tax law noncompliance negative factor weighs against
relief. The record indicates that petitioner had not filed tax
returns for 2000 or 2001 as of April 20, 2002.
The requesting spouse’s legal obligation negative factor
does not weigh against relief. As noted above, petitioner did
not enter an agreement with Mr. George with regard to payment of
the liability.
Taking into account all the facts and circumstances, we
conclude that it would not be inequitable to hold petitioner
liable for the unpaid liability. Petitioner has not carried her
burden to establish that respondent’s denial of equitable relief
pursuant to section 6015(f) was an abuse of discretion.10 We
have considered all of petitioner’s arguments and contentions
10That the facts of the instant case were fully stipulated
does not relieve petitioner of the burden of proof. Rule 149(b).
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