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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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