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spouse’s legal obligation, (5) significant benefit, (6)
compliance with income tax laws, (7) abuse, and (8) mental or
physical health. Further, Rev. Proc. 2003-61, supra, provides
that no single factor will be determinative, but that all
relevant factors, regardless of whether the factor is listed in
Rev. Proc. 2003-61, sec. 4.03, will be considered and weighed.
A. Marital Status
Rev. Proc. 2003-61, supra, provides that petitioner’s
marital status is a factor in determining whether a spouse should
be granted equitable relief. Petitioner and Mr. Bennett divorced
on May 8, 2000, and her divorce weighs in favor of granting
equitable relief under section 66(c).
B. Economic Hardship
Whether a spouse will suffer economic hardship if equitable
relief is not granted under section 66(c) is a factor which may
be considered pursuant to Rev. Proc. 2003-61, supra. Economic
hardship exists if a levy will cause a taxpayer to be unable to
pay his or her reasonable basic living expenses. Sec. 301.6343-
1(b)(4), Proced. & Admin. Regs.
In this case, we are unable to properly evaluate whether
petitioner would suffer economic hardship if equitable relief
were not granted. While petitioner testified that she was
economically dependent upon Mr. Bennett during their marriage, we
are not aware of petitioner’s current employment situation or
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