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decree or agreement to pay the liability. See Rev. Proc. 2000-
15, sec. 4.03(2), 2000-1 C.B. at 449. Our analysis of the
factors and the parties’ arguments follows.
Marital Status
Respondent concedes that this factor weighs in favor of
granting relief.
Economic Hardship
At trial, petitioner alleged that, in the past, she had
experienced economic hardship attributable to the 1998 joint
liability,5 but petitioner offered no financial information in
support of her allegation. Petitioner has not alleged that she
is currently experiencing, or would experience, economic hardship
if she is not relieved of the 1998 joint liability. In the
absence of any evidence of economic hardship, we must conclude
that this factor weighs against granting relief.
Abuse
Petitioner has not alleged that Mr. Wollow abused her.
Consequently, this factor is neutral.
5According to petitioner, during 2000, when respondent
applied petitioner’s 1999 refund to offset the 1998 joint
liability, petitioner was a single parent with one daughter in
her custody during 70 percent of the year and another daughter in
college. Petitioner testified that, after paying the bills, “not
too much [was] left over.”
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