Yvonne C. Lopez - Page 10

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          the provisions providing relief from joint and several liability            
          are “‘designed to protect the innocent, not the intentionally               
          ignorant’”.  Morello v. Commissioner, T.C. Memo. 2004-181                   
          (quoting Dickey v. Commissioner, T.C. Memo. 1985-478).                      
          Petitioner has not established that she did not have reason to              
          know the tax liabilities shown on her returns for the years at              
          issue would not be paid when she signed them and that it was                
          reasonable for her to believe Mr. Cowdery would pay those                   
          liabilities.  Consequently, petitioner does not satisfy the                 
          knowledge or reason to know element of Rev. Proc. 2000-15, sec.             
          4.02 and does not qualify for equitable relief under that section           
          of the revenue procedure.  For the sake of completeness, however,           
          we also address the economic hardship factor.                               
               2.   Economic Hardship                                                 
               Rev. Proc. 2000-15, sec. 4.02 requires that the                        
          determination of whether a requesting spouse will suffer economic           
          hardship be based on rules similar to those in section 301.6343-            
          1(b)(4), Proced. & Admin. Regs.  Rev. Proc. 2000-15, sec.                   
          4.02(1)(c).  Economic hardship is present if satisfaction of the            














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