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2002, almost 8 months after it was due; and (4) she paid the tax
she owed for 2002 on October 19, 2003, about 6 months after it
was due.
We agree with respondent that petitioner failed to make a
good faith effort to comply with income tax laws for tax years
following the tax years in issue, 1991 through 1999. See Castle
v. Commissioner, T.C. Memo. 2002-142 (requesting spouse failed to
establish compliance factor did not apply against her where she
provided no explanation for filing return for subsequent tax year
more than 1 year late); cf. Ewing v. Commissioner, 122 T.C. at
46-47.
This factor weighs against granting petitioner relief.
7. Attribution Factor for 1999
As previously discussed, respondent acknowledges that the
attribution factor weighs in favor of granting petitioner relief
for 1991 through 1998. Section 4.03(1)(f) of Rev. Proc. 2000-15,
2000-1 C.B. at 448-449, provides that the fact that the liability
for which relief is sought is solely attributable to the
nonrequesting spouse weighs in favor of relief. Section
4.03(2)(a) of Rev. Proc. 2000-15, 2000-1 C.B. at 449, provides
that the fact that the unpaid liability is attributable to the
requesting spouse weighs against granting relief. Respondent
contends that the attribution factor does not weigh in favor of
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