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event, the record suggests that she would have substantial equity
in the residence after satisfaction of those tax liabilities and
discharge of any other liens.
Petitioner’s situation is dissimilar to the situations of
those taxpayers who were living at or near poverty level at the
time of their request for relief from joint and several liability
and who proved that they would suffer economic hardship without
relief. See, e.g., Washington v. Commissioner, 120 T.C. at
149-150; Foor v. Commissioner, T.C. Memo. 2004-54; Ferrarese v.
Commissioner, T.C. Memo. 2002-249; August v. Commissioner, T.C.
Memo. 2002-201; Rowe v. Commissioner, T.C. Memo. 2001-325. On
the record in this case, petitioner has not persuaded us that the
economic hardship factor weighs in favor of granting her relief.
In order to satisfy the knowledge or reason to know factor
under the circumstances of this case, petitioner must establish
that it was reasonable for her to believe that intervenor would
pay the additions to tax and interest at the times that she
signed those returns. See, e.g., Ewing v. Commissioner, 122 T.C.
at 47-48; Hopkins v. Commissioner, 121 T.C. at 88-89; Washington
v. Commissioner, supra at 150-151; Morello v. Commissioner, T.C.
Memo. 2004-181; Keitz v. Commissioner, T.C. Memo. 2004-74;
Foor v. Commissioner, supra; Ogonoski v. Commissioner, T.C. Memo.
2004-52; Wiest v. Commissioner, T.C. Memo. 2003-91; Collier v.
Commissioner, T.C. Memo. 2002-144.
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