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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 the
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