Tammy Debra Martin - Page 9

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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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