- 29 - 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 bePage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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