Donna M. Keitz - Page 13

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          additional claimed expenses.  Petitioner has failed to establish            
          that she will suffer economic hardship if equitable relief is not           
          granted.  The Court concludes that petitioner has not satisfied             
          this element.  Accordingly, the Court concludes that petitioner             
          fails to qualify for relief under Rev. Proc. 2000-15, sec. 4.02.            
          Balancing Factors for Determining Whether To Grant Equitable                
          Relief Under Rev. Proc. 2000-15                                             
               Where, as here, the requesting spouse fails to qualify for             
          relief under Rev. Proc. 2000-15, sec. 4.02, the Commissioner may            
          nonetheless grant the requesting spouse relief under Rev. Proc.             
          2000-15, sec. 4.03.                                                         
               Rev. Proc. 2000-15, sec. 4.03, lists the following two                 
          factors, which if present, the Commissioner weighs in favor of              
          granting relief:  (1) The taxpayer is separated or divorced from            
          the nonrequesting spouse; and (2) the taxpayer was abused by his            
          or her spouse; and the following two factors, which if present,             
          the Commissioner weighs against granting relief:  (3) The                   
          taxpayer received significant benefit from the unpaid liability             
          or the item giving rise to the deficiency; and (4) the taxpayer             
          has not made a good faith effort to comply with Federal income              
          tax laws in the tax years following the tax year to which the               
          request for relief relates.  Ewing v. Commissioner, 122 T.C. at             
          ____ (slip op. at 22-24).                                                   








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