- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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