Yvonne C. Lopez - Page 14

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          factors is not intended to be exhaustive.  See Washington v.                
          Commissioner, 120 T.C. at 148; Jonson v. Commissioner, 118 T.C.             
          at 125.                                                                     
              Rev. Proc. 2000-15, sec. 4.03(1) lists the following six               
          positive factors that the Commissioner will weigh in favor of               
          granting equitable relief:                                                  
                    (a) Marital status.  The requesting spouse is                     
               separated * * * or divorced from the nonrequesting                     
               spouse.                                                                
                    (b) Economic hardship.  The requesting spouse                     
               would suffer economic hardship (within the meaning of                  
               section 4.02(1)(c) of this revenue procedure) if relief                
               from the liability is not granted.                                     
                    (c) Abuse.  The requesting spouse was abused by                   
               the nonrequesting spouse, but such abuse did not amount                
               to duress.                                                             
                    (d) No knowledge or reason to know.  In the case                  
               of a liability that was properly reported but not paid,                
               the requesting spouse did not know and had no reason to                
               know that the liability would not be paid.  * * *                      
                    (e) Nonrequesting spouse’s legal obligation.  The                 
               nonrequesting spouse has a legal obligation pursuant to                
               a divorce decree or agreement to pay the outstanding                   
               liability.  This will not be a factor weighing in favor                
               of relief if the requesting spouse knew or had reason                  
               to know, at the time the divorce decree or agreement                   
               was entered into, that the nonrequesting spouse would                  
               not pay the liability.                                                 
                    (f) Attributable to nonrequesting spouse.  The                    
               liability for which relief is sought is solely                         
               attributable to the nonrequesting spouse.                              
          Rev. Proc. 2000-15, sec. 4.03(2) lists the following six negative           
          factors that the Commissioner weighs against granting equitable             
          relief:                                                                     





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