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normal support. Petitioner’s failure to show that she had no
reason to know that the taxes would not be paid, and that payment
of part or all of the taxes would cause her economic hardship are
negative factors. Under Rev. Proc. 2000-15, sec. 4.03(2)(b),
reason to know that the tax would not be paid “is an extremely
strong factor weighing against relief.” The revenue procedure
provides that “when the factors in favor of equitable relief are
unusually strong, it may be appropriate to grant relief under
section 6015(f) in limited situations” where the spouse
requesting relief had reason to know of the understatement. Id.
The Court finds no “unusually strong” factors in favor of
equitable relief here.
Petitioner has alleged that she suffered abuse at the hands
of her husband. If true, it would be another factor in her
favor. Rev. Proc. 2000-15, sec. 4.03(1)(c), 2000-1 C.B. at 444.
The record includes copies of several “Miscellaneous Incident”
reports prepared by officers of the Glen Ellyn police department.
The reports, most of which postdate the years at issue, do show
that petitioner and her husband often did not get along: They
argued loudly and, on one occasion, engaged in a “mutual shoving
match”. The reports do not, however, show that petitioner was
“abused” by her husband.
Petitioner has three factors in her favor and two that weigh
against her. In view of the language of Rev. Proc. 2000-15, sec.
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