Helen M. Korchak - Page 57

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          section 6015(b)(1)(D), see id., is whether in signing the tax               
          return the requesting spouse did not know, and had no reason to             
          know, of an understatement in that return, see Rev. Proc. 2003-             
          61, sec. 4.03(2)(a)(iii)(B), 2003-2 C.B. 296, 298.  Moreover, in            
          determining whether a requesting spouse satisfies section                   
          6015(b)(1)(D), we may consider, inter alia, whether such spouse             
          satisfies section 6015(b)(1)(C).29  We have found that petitioner           
          satisfies section 6015(b)(1)(C) for her taxable year 1982.  We              
          further find that in signing the 1982 joint tax return petitioner           
          did not know, and had no reason to know, of the understatement in           
          that return for purposes of section 6015(b)(1)(D).                          
               Other relevant factors that we may consider in determining             
          whether a requesting spouse satisfies section 6015(b)(1)(D)                 
          include whether (1) the requesting spouse was deserted, divorced,           
          or separated (marital status factor); (2) the requesting spouse             
          would suffer economic hardship if relief were not granted (eco-             
          nomic hardship factor); and (3) the requesting spouse made a good           
          faith effort to comply with the tax laws for the taxable years              
          following the taxable year to which the request for relief                  
          relates (tax compliance factor).  See Washington v. Commissioner,           
          120 T.C. 137, 147 (2003); Alt v. Commissioner, supra at 314-316.            






               29See Halton v. Commissioner, T.C. Memo. 2005-209.                     




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