Judith A. Madden - Page 13

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         attributable to the nonrequesting spouse.  Rev. Proc. 2000-15,               
         sec. 4.03(2), 2000-1 C.B. at 449, lists the following six factors            
         as weighing against granting relief for an unpaid liability:  (1)            
         The unpaid liability is attributable to the requesting spouse;               
         (2) the requesting spouse knew or had reason to know at the time             
         the return was signed that the reported liability would be                   
         unpaid; (3) the requesting spouse significantly benefited (beyond            
         normal support) from the unpaid liability; (4) the requesting                
         spouse will not suffer economic hardship if relief is denied; (5)            
         the requesting spouse has not made a good faith effort to comply             
         with Federal income tax laws in the tax years following the tax              
         year to which the request for relief relates; and (6) the                    
         requesting spouse has a legal obligation pursuant to a divorce               
         decree or agreement to pay the unpaid liability.  In addition,               
         Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, states:  “No              
         single factor will be determinative of whether equitable relief              
         will or will not be granted in any particular case.  Rather, all             
         factors will be considered and weighed appropriately.”                       
              Furthermore, the list of aforementioned factors is not                  
         intended to be exhaustive.  In deciding whether respondent’s                 
         determination that petitioner is not entitled to relief under                
         section 6015(f) was an abuse of discretion, we consider evidence             
         relating to all the facts and circumstances.                                 

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