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– Attributable to nonrequesting spouse. Petitioner has
failed to show that the remaining 1999 liability is solely
attributable to intervenor; conversely, he has failed to
establish the extent to which such liability is not attributable
to him. This factor is negative.
– Significant benefit. There is no evidence bearing upon
whether petitioner did or did not significantly benefit from the
unpaid 1999 liability. This factor is neutral.
– Noncompliance with Federal tax laws. There is no evidence
regarding petitioner’s compliance with Federal income tax laws in
the tax years following 1999. This factor is neutral.
Of the factors listed in section 4.03 of Rev. Proc. 2000-15,
one is positive, three are negative, and four are neutral.
Petitioner has brought to our attention no circumstances beyond
those encapsulated by the section 4.03 factors. Our own
judgment, considering those factors, is that it is not
inequitable to hold petitioner liable for the unpaid 1999
liability. Respondent therefore did not act arbitrarily,
capriciously, or without sound basis in fact by not granting
petitioner relief from that liability.
III. Conclusion
Respondent did not abuse his discretion in denying
petitioner equitable relief from the unpaid 1999 liability.
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Last modified: May 25, 2011