Kathleen E. Gilliam - Page 11

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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             
               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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