Nancy M. O'Neill, Petitioner, and Robert B. Wollow, Intervenor - Page 8

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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.                            
               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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