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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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