- 16 -
Commissioner, 120 T.C. at 149. The Court concludes that this
factor is neutral.
3. Significant Benefit
Respondent determined that petitioner did not gain any
significant benefit from the unpaid liability. The Court
concludes that this factor favors petitioner. See Ewing v.
Commissioner, supra at _____ (slip op. at 22-23).
4. Compliance With Tax Laws
Petitioner filed returns for tax years 1995 through 1997,
and respondent concedes that petitioner has complied with tax
laws at least since 1996. Rev. Proc. 2000-15, supra, lists tax
compliance as a factor which the Commissioner will consider only
against granting relief. The Court concludes that this factor is
neutral.
5. Economic Hardship
As discussed, supra, petitioner has failed to establish that
she will suffer economic hardship if equitable relief is not
granted. The Court concludes that this factor weighs against
petitioner.
6. Knowledge or Reason To Know
The Court has considered supra respondent's argument that
petitioner at the time she signed the return knew or had reason
to know that the tax due would not be paid. The Court rejects
respondent's argument that she possessed such knowledge or failed
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