- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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