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liabilities) would not bar respondent from undertaking future
collection action against petitioner upon the unpaid tax
liabilities. Although Levy earned substantial income as an
oncological surgeon, he lacked current assets sufficient to pay
the tax liabilities. Additionally, if petitioner were granted
relief as an innocent spouse from joint liability for 1991 under
section 6015(b) or (f), she would be entitled to a $24,300.13
refund attributable to previously levied real estate
commissions. See sec. 6015(g)(1), (3); Washington v.
Commissioner, 120 T.C. at 153-154.
This factor weighs in favor of granting petitioner equitable
relief for 1991 through 1999. Cf. Knorr v. Commissioner, T.C.
Memo. 2004-212.
2. Abuse Factor
Petitioner does not assert that she was abused by Levy or
otherwise coerced into executing the 1991 through 1999 joint
returns. Lack of spousal abuse is not a factor listed in section
4.03(2) of Rev. Proc. 2000-15, 2000-1 C.B. at 449, that weighs
against granting equitable relief. Therefore, this factor is
neutral. See Washington v. Commissioner, supra at 149.
3. Economic Hardship Factor
Rev. Proc. 2000-15, sec. 4.02(1)(c), 2000-1 C.B. at 448,
provides that the determination of whether a requesting spouse
will suffer economic hardship if relief is not granted will be
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