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(b) At the time the return was signed, the
requesting spouse had no knowledge or reason to know
that the tax would not be paid. The requesting spouse
must establish that it was reasonable for the
requesting spouse to believe that the nonrequesting
spouse would pay the reported liability * * *; and
(c) The requesting spouse will suffer economic
hardship if relief is not granted * * *.
If relief is not available under Rev. Proc. 2000-15, sec.
4.02, the Commissioner may nevertheless grant relief under the
general provisions of Rev. Proc. 2000-15, sec. 4.03(1), 2000-1
C.B. at 448, which provides a list of factors the Commissioner
considers when deciding whether to grant relief. No single
factor will be determinative of whether equitable relief will be
granted in any particular case. Rather, all factors will be
considered and weighed appropriately. The list of factors is not
intended to be exhaustive. See Washington v. Commissioner, supra
at 147-148; Jonson v. Commissioner, supra at 125.
Rev. Proc. 2000-15, sec. 4.03, lists the following four
factors whose presence the Commissioner weighs in favor of
granting relief and whose absence the Commissioner weighs against
granting relief: (1) The requesting spouse would suffer economic
hardship if relief is denied; (2) the unpaid liability is
attributable to the nonrequesting spouse; (3) 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 the reported
liability would be unpaid at the time the return was signed (the
absence of this factor is an “extremely strong factor weighing
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