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f. Requesting Spouse’s Legal Obligation
The record is also devoid of any information regarding
whether petitioner has a legal obligation pursuant to a divorce
decree or agreement to pay the liability.
Counterbalancing the factors weighing against relief are the
factors weighing in favor of relief. We next review each of the
following six factors, as listed under Rev. Proc. 2000-1, sec.
4.03(1), to evaluate whether they serve as a makeweight for
equitable relief under section 6015(f):
a. Marital Status
Petitioner is separated or divorced from Mr. Vuxta. He died
on May 4, 2001, a year before petitioner made her request for
relief from joint and several liability. This factor is squarely
in favor of petitioner.
b. Economic Hardship
As we indicated earlier, petitioner has not shown that she
will suffer economic hardship if relief is not granted.
c. Abuse
There is nothing in the record indicating that petitioner
was subject to abuse.
d. No Knowledge or Reason To Know
As we indicated earlier, petitioner knew or had reason to
know that the reported liabilities for 1990 and 1991 would be
unpaid at the time the corresponding returns were signed.
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