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(8) Whether the requesting spouse made a good faith
effort to comply with the Federal income tax laws in years
following the years to which the request for relief relates.
Generally, no single factor will control whether equitable
relief will be granted in a particular case. Rather, all
relevant facts will be considered and weighed appropriately, and
the above guidelines are not intended to be exhaustive. Ewing v.
Commissioner, 122 T.C. at 48; Rev. Proc. 2000-15, sec. 4.03(2).
For example, other factors that have been considered by this
Court include whether an understatement or underpayment of tax
was the result of concealment, overreaching, or other wrongdoing
on the part of the nonrequesting spouse. See, e.g., Ewing v.
Commissioner, 122 T.C. at 48-49.
In Lopez v. Commissioner, T.C. Memo. 2005-36, relief was not
granted because, although various facts weighed in favor of the
taxpayer, the taxpayer’s knowledge and financial resources
weighed heavily against granting relief. In Keitz v.
Commissioner, T.C. Memo. 2004-74, relief was granted because the
taxpayer’s lack of knowledge of the underpayment outweighed the
absence of economic hardship.
As listed below, in this case, it has been established that
most of the guidelines or factors listed in Rev. Proc. 2000-15,
supra, weigh in favor of granting petitioner relief from joint
tax liability for 1993, 1994, and 1995 with regard to the unpaid
taxes attributable to Alimam’s income from his medical practice:
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