- 7 -
Cir. 2003). Moreover, the list of factors is not intended to be
exhaustive. See Washington v. Commissioner, supra at 148.
The following six factors weigh in favor of granting relief
for the liability: (1) The requesting spouse is separated or
divorced from the nonrequesting spouse; (2) the requesting spouse
would suffer economic hardship if relief is denied; (3) the
nonrequesting spouse abused the requesting spouse; (4) the
requesting spouse did not know or have reason to know that the
liability would not be paid; (5) the nonrequesting spouse has a
legal obligation pursuant to a divorce decree or agreement to pay
the liability; and (6) the liability is solely attributable to
the nonrequesting spouse. See Rev. Proc. 2000-15, sec. 4.03(1),
2000-1 C.B. at 448-449. On the other hand, the following six
factors weigh against granting relief for the liability: (1) The
unpaid liability is attributable to the requesting spouse; (2)
the requesting spouse knew or had reason to know when she signed
the return that the reported liability would be unpaid; (3) the
requesting spouse significantly benefited (beyond the normal
support) from the unpaid liability; (4) the requesting spouse
will not experience economic hardship if relief is denied; (5)
the requesting spouse 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; and (6) the
requesting spouse had a legal obligation pursuant to a divorce
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