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settlement of property rights of the parties. However,
petitioner has not provided respondent’s counsel or this Court
with a copy of the aforesaid agreement.
Rev. Proc. 2000-15, sec. 4.03(1)(e), indicates that if Mr.
Glaze had a legal obligation under the judgment for dissolution
of marriage to pay the tax liabilities, then that fact would
weigh in favor of granting relief to petitioner. Likewise, if
the judgment for dissolution of marriage had placed the
obligation to pay the taxes on petitioner, then that fact would
weigh against granting relief to her as indicated in Rev. Proc.
2000-15, sec. 4.03(2)(f). In the present case, the divorce
decree has not been offered into evidence. Thus, this is a
neutral factor.
6. Attributable to Nonrequesting Spouse
As previously stated, $36,400 of petitioner’s and Mr.
Glaze’s unreported income for taxable year 1995 is attributable
to wages earned through Mr. Glaze’s employment with Mayflower.
The additional $24 of interest income was received by petitioner
and Mr. Glaze in both their names and is therefore attributable
to both petitioner and Mr. Glaze. As to the $36,400 of
petitioner’s and Mr. Glaze’s unreported income for taxable year
1995, this factor favors granting petitioner equitable relief.
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