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petitioner introduced no evidence of her basic living expenses or
other current debts that would show she could not pay her current
reasonable basic living expenses. Accordingly, petitioner has
failed to establish that she will suffer economic hardship if
equitable relief is not granted. The Court concludes that
petitioner has not satisfied this element. Therefore, the Court
concludes that petitioner fails to qualify for relief under Rev.
Proc. 2000-15, sec. 4.02.
If the requesting spouse satisfies the threshold conditions
of Rev. Proc. 2000-15, sec. 4.01, but does not qualify for relief
under Rev. Proc. 2000-15, sec. 4.02, the Commissioner looks to
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, to determine
whether the taxpayer should be granted equitable relief.
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 will
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,
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