Tammy Debra Martin - Page 7

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          taxes would be paid if she did not pay them.  The Court finds               
          that petitioner has not shown that at the time she signed the               
          returns she had no reason to know that the taxes would not be               
          paid.                                                                       
               In determining whether a requesting spouse will suffer                 
          economic hardship if relief is not granted, Rev. Proc. 2000-15,             
          supra, looks to section 301.6343-1(b)(4), Proced. & Admin. Regs.,           
          for guidance.  Rev. Proc. 2000-15, sec. 4.02(1)(c), 2000-1 C.B.             
          at 448.  Economic hardship is present if satisfaction of the tax            
          liability in whole or in part will cause the taxpayer to be                 
          unable to pay reasonable basic living expenses.  Sec.                       
          301.6343-1(b)(4), Proced. & Admin. Regs.  Petitioner offered no             
          evidence that payment of part or all of the taxes due would cause           
          her financial hardship.                                                     
               Where, as here, the requesting spouse fails to qualify for             
          relief under Rev. Proc. 2000-15, sec. 4.02, the Commissioner may            
          nonetheless grant the requesting spouse relief under Rev. Proc.             
          2000-15, sec. 4.03.  Rev. Proc. 2000-15, sec. 4.03(1) and (2),              
          2000-1 C.B. at 448, sets forth six positive and six negative                
          factors that are to be considered in determining whether to grant           
          relief.  The revenue procedure makes clear that no single factor            
          is to be determinative in any particular case, that all factors             
          are to be considered and weighed appropriately, and that the list           
          of factors is not intended to be exhaustive.                                






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