Tracie Young - Page 18

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         hardship if required to pay some or all of the tax deficiency.               
         Petitioner has not entered into evidence any documentation or                
         testimony to contradict the above claims or the determination of             
         respondent; therefore, we find that petitioner will not suffer               
         economic hardship if relief is not granted.  This factor favors              
         denying relief.                                                              
         3.  Abuse                                                                    
              There is no evidence in the record that petitioner was                  
         abused by Mr. Glaze.  Spousal abuse is a factor listed in Rev.               
         Proc. 2000-15, sec. 4.03(1), that will weigh in favor of                     
         equitable relief if found but will not weigh against equitable               
         relief if not present in a case.  Therefore, this factor is                  
         neutral.                                                                     
         4.  Knowledge or Reason To Know                                              
              In the case of an income tax liability that arose from a                
         deficiency, the fact that the requesting spouse did not know and             
         had no reason to know of the item giving rise to the deficiency              
         is a factor in favor of granting relief.  Rev. Proc. 2000-15,                
         sec. 4.03(1)(d).  By contrast, the fact that the requesting                  
         spouse knew or had reason to know of the item giving rise to the             
         deficiency is a factor weighing against relief.  Rev. Proc. 2000-            
         15, sec. 4.03(2)(b).                                                         









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