- 42 - granting petitioner relief for 1999, as some of the liability for that year is attributable to her. Because the weight of all other factors weighs against granting petitioner relief for the taxable years 1996 through 1999, we need not decide the extent to which the attribution factor affects granting petitioner relief for 1999. 8. Other Factor Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, acknowledges that the factors listed therein are not exhaustive. Despite this, respondent did not consider the fact that petitioner did not participate in any wrongdoing with respect to the unpaid 1991 through 1995 tax liabilities. As previously discussed, petitioner from the time she signed the returns for those years until 1997, reasonably believed Levy would pay the 1991 through 1995 balance due amounts. The problem originated with Levy, who, as discussed above, concealed from petitioner his nonpayment of those tax liabilities and his serious gambling problem. See Ewing v. Commissioner, 122 T.C. at 48-49 (holding that husband’s concealment from taxpayer of his nonpayment of tax liability was a factor supporting taxpayer’s claim for relief under section 6015(f)). With respect to the 1996 through 1999 tax liabilities, however, as discussed supra, petitioner had reason to know Levy would not pay those liabilities at the time she signed thePage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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