- 57 -
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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