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whether to grant relief under section 6015(f). Rev. Proc. 2000-
15, sec. 4.03(1), lists the following six factors weighing in
favor of granting relief for an unpaid 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 requesting spouse was abused by the
nonrequesting spouse; (4) the requesting spouse did not know or
have reason to know that the reported liability would not be
paid; (5) the nonrequesting spouse has a legal obligation
pursuant to a divorce decree or agreement to pay the unpaid
liability; and (6) the unpaid liability is attributable to the
nonrequesting spouse. Rev. Proc. 2000-15, sec. 4.03(2), 2000-1
C.B. at 449, lists the following six factors weighing against
granting relief for an unpaid liability: (1) The unpaid
liability is attributable to the requesting spouse; (2) the
requesting spouse knew or had reason to know that the reported
liability would be unpaid at the time the return was signed; (3)
the requesting spouse significantly benefited (beyond normal
support) from the unpaid liability; (4) the requesting spouse
will not suffer 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 has a legal obligation pursuant to a divorce decree or
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Last modified: May 25, 2011