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failed to establish she will suffer economic hardship if she is
not granted equitable relief. This positive factor does not
apply.
c. Abuse by Nonrequesting Spouse
Petitioner does not allege that Mr. Cowdery abused her.
This positive factor does not apply. Ewing v. Commissioner,
supra at 46; Washington v. Commissioner, supra at 149.
d. No Knowledge or Reason To Know
For the reasons stated in our analysis of this factor under
Rev. Proc. 2000-15, sec. 4.02, we conclude petitioner has failed
to establish that she did not have reason to know when the
returns were filed that the tax liabilities shown as due on the
1992, 1993, 1994, and 1995 returns would not be paid. This
positive factor does not apply.
e. Nonrequesting Spouse’s Legal Obligation
Under petitioner and Mr. Cowdery’s 1997 divorce decree, Mr.
Cowdery bears the legal obligation for paying the tax liabilities
for each of the years in issue. Respondent concedes this factor
weighs in favor of granting relief.
f. Liabilities Solely Attributable to Nonrequesting
Spouse
The unpaid tax liabilities resulted from underwithholding of
both petitioner’s and Mr. Cowdery’s wages, and, therefore, the
liabilities are not solely attributable to Mr. Cowdery.
Consequently, we conclude this positive factor does not apply.
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