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income attributable to petitioner. Attribution to the
nonrequesting spouse weighs in favor of relief and attribution to
the requesting spouse weighs against relief. Rev. Proc. 2000-15,
sec. 4.03(1)(f), (2)(a), 2000-1 C.B. at 449. Second, petitioner
admitted that she did not review the joint return prior to
filing. Thus, petitioner knew or had reason to know of the
omission of her income. Rev. Proc. 2000-15, sec. 4.03(1)(d),
(2)(b), 2000-1 C.B. at 449. Lastly, petitioner had a legal
obligation pursuant to her divorce decree to pay the liability.
Rev. Proc. 2000-15, sec. 4.03(2)(f).
On these facts, we conclude that respondent did not abuse
his discretion in denying petitioner’s request for equitable
relief. Accordingly, we sustain respondent’s determination that
petitioner is ineligible for relief under section 6015(f).
We note the following two adjustments to the 1995 tax
liability. On April 15, 1999, respondent applied an overpayment
of $2,557 from petitioner’s 1998 income tax return to the joint
tax liability from 1995. On June 21, 2000, respondent allowed
$1,019 as an itemized deduction for State income tax paid for
1995, which resulted in an abatement of $316.
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