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ii. Economic Hardship
As indicated above, petitioner may well suffer economic
hardship if relief is not granted.
iii. Abuse
There is nothing in the record indicating that petitioner
was subject to abuse.
iv. No Knowledge or Reason To Know
As indicated above, petitioner knew or should have known
that her wages were not included on the tax return.
v. Nonrequesting Spouse’s Legal Obligation
There is nothing in the record indicating whether Mr.
Gilliam, the nonrequesting spouse, had a legal obligation
pursuant to the divorce decree or agreement to pay the
outstanding tax liability.
vi. Attributable to Requesting Spouse
As indicated above, the omitted item of income was that of
petitioner.
Having considered the facts and circumstances in this case,
especially in light of the factors in Rev. Proc. 2000-15, sec.
4.03, we conclude that petitioner is not entitled to relief under
section 6015(f). While some of the factors are neutral, many of
the factors weigh against relief. In particular, the omitted
items of income and the understatement resulting therefrom are
attributable to petitioner, rather than Mr. Gilliam. In
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