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agreement to pay the unpaid liability. This list is not
exhaustive, no single factor is determinative, and all factors
should be considered and weighed appropriately. Rev. Proc. 2000-
15, sec. 4.03.
Respondent agrees that petitioner will suffer economic
hardship if relief is not granted. The joint liabilities along
with penalties and interest have grown to over $278,000.
Petitioner earns $2,000 per month, and Mr. Sjodin is retired
earning occasional real estate income and Social Security. This
factor weighs in petitioner’s favor.
The parties have stipulated that the liabilities are
attributable at least in small part to petitioner’s income.
Petitioner and Mr. Sjodin are not divorced or separated, and
there is no divorce decree or agreement in which Mr. Sjodin
assumed responsibility for the payment of the outstanding
liabilities. We do not hold it against petitioner that she
admirably remained committed to her marriage, and we agree that
in certain cases relief is appropriate for taxpayers who are
married at the time relief is requested. However, this factor is
neutral in our analysis.
The parties have stipulated that Mr. Sjodin did not
physically abuse petitioner. Petitioner argues that Mr. Sjodin
mentally abused her. We presume that her position is that Mr.
Sjodin’s controlling and secretive nature was abusive. We do not
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Last modified: May 25, 2011