Teresa J. Fox - Page 13

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          economic hardship, the question of benefit from the underpayment            
          and refund, the absence of a legal obligation of Mr. Shattun to             
          pay the tax, and petitioner’s mental condition.  The factors                
          weighing against relief are petitioner’s actual knowledge of the            
          item giving rise to the deficiency and her unexplained failure to           
          timely file tax returns for 2002 and 2003.  On this record we               
          conclude that respondent’s denial of equitable relief for                   
          petitioner from joint Federal income tax liability for 2000 under           
          section 6015(f) was not an abuse of discretion.                             
               To reflect the foregoing,                                              

                                                       Decision will be               
                                                  entered for respondent.             

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