- 43 - returns for those years. See Knorr v. Commissioner, T.C. Memo. 2004-212 (noting Tax Court’s consistent application of principle that provisions providing relief from joint and several liability were designed to protect the innocent, not the intentionally ignorant); cf. Ewing v. Commissioner, 122 T.C. at 47-49. Levy’s concealment of his nonpayment of taxes and gambling problem weighs in favor of granting petitioner relief for 1991 through 1995, but not for 1996 through 1999. 9. Conclusions Although it is undisputed that petitioner meets the threshold conditions of section 4.01 of Rev. Proc. 2000-15, supra, she does not qualify for relief under section 6015(f) for 1991 through 1999 under section 4.02 of Rev. Proc. 2000-15 because, among other things, she has failed to establish that she will suffer economic hardship if relief is not granted. Petitioner, however, may still qualify for relief under section 6015(f) if, taking into account all the facts and circumstances, it is inequitable to hold petitioner liable for all or part of the unpaid liability. Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448-449. As previously discussed, petitioner had no knowledge or reason to know, at the time she signed the returns for 1991 through 1995, that Levy would not pay those tax liabilities. Indeed, Levy concealed from her for some time his nonpayment ofPage: 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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