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Rev. Proc. 2000-15, sec. 4.03(2)(f). In the present case where
the divorce decree holds each party equally responsible for all
Federal income tax liabilities of the parties from the date of
marriage through December 31, 1998, this factor is considered
neutral.
6. Attributable to Nonrequesting Spouse
As previously stated, the majority of the income tax
liability for taxable year 1995 was a result of petitioner’s wage
income. However, the income tax liabilities of $1,509.92 and
$822.64 for taxable years 1997 and 1998, respectively, are
attributable to Mr. Tillotson’s self employment and his failure
to pay any estimated taxes. As to the income tax liabilities of
$1,509.92 and $822.64 for taxable years 1997 and 1998,
respectively, this factor favors granting petitioner equitable
relief.
7. Significant Benefit
Respondent contends that petitioner received benefits from
the proceeds of Mr. Tillotson’s self-employment in the form of
payment of joint household expenses and living expenses.
Petitioner testified at trial that Mr. Tillotson would pay
household and living expenses with both his paychecks and her
paychecks. Petitioner also testified at trial that Mr. Tillotson
was responsible for paying the bills. Rev. Proc. 2000-15, sec.
4.03(2)(c), states that “The requesting spouse has significantly
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