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because petitioner failed to provide any evidence establishing
abuse.
In addition, Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at
448, lists the following two factors that, if true, the
Commissioner weighs against granting relief and that, if not
true, are neutral: (1) The taxpayer received a significant
benefit from the unpaid liability and (2) the taxpayer has not
made a good faith effort to comply with the Federal income tax
laws in the tax years following the tax year to which the request
for relief relates. The significant benefit factor is neutral in
this case because neither evidence nor argument has been
presented as to whether this factor weighs against petitioner.
The noncompliance factor weighs against petitioner because, as of
April 29, 2004, she had not filed Federal income tax returns for
either 1997 or 1999, and the explanations that petitioner gave
during her testimony as to why she had not filed those returns
were uncorroborated and unconvincing.
Finally, Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448,
lists the following four factors that, if true, the Commissioner
weighs in favor of granting relief and that, if not true, the
Commissioner weighs against granting relief: (1) The taxpayer
would suffer economic hardship if relief were denied; (2) in the
case of a liability that was properly reported but not paid, the
requesting spouse did not know and had no reason to know that the
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