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weighing against granting relief for an unpaid liability: (1)
The unpaid liability is attributable to the requesting spouse;
(2) the requesting spouse knew or had reason to know that the
reported liability would be unpaid at the time the return was
signed; (3) the requesting spouse benefited (beyond normal
support) from the unpaid liability; (4) the requesting spouse
will not suffer economic hardship if relief is denied; (5) the
requesting spouse has not made a good faith effort to comply with
Federal income tax laws in the tax years following the tax year
or years to which the request for relief relates; and (6) the
requesting spouse has a legal obligation pursuant to a divorce
decree or agreement to pay the unpaid liability. In addition,
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448-449, states:
“No single factor will be determinative of whether equitable
relief will or will not be granted in any particular case.
Rather, all factors will be considered and weighed
appropriately.” Furthermore, the list of aforementioned factors
is not intended to be exclusive.
In deciding whether respondent’s determination that
petitioner is not entitled to relief under section 6015(f) was an
abuse of discretion, we consider evidence relating to all the
facts and circumstances. See generally Washington v.
Commissioner, supra at 148.
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