Judith A. Madden - Page 14

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              In accordance with the above, we will consider each of the              
         factors enumerated in Rev. Proc. 2000-15, sec. 4.03.  We will                
         also consider whether any additional facts alleged by the parties            
         affect the analysis of whether respondent abused his discretion              
         in denying petitioner equitable relief under section 6015(f).                
         A.   Neutral Factors                                                         
              We consider many of the factors to be neutral, weighing                 
         neither in favor of nor against granting petitioner relief.                  
              1.   Marital Status                                                     
              Petitioner is still married and living with Mr. Sturges.                
         Consequently, this factor does not apply.  See Ewing v.                      
         Commissioner, 122 T.C. 32, 46 (2004).                                        
              2.   Economic Hardship                                                  
              An analysis of economic hardship under Rev. Proc. 2000-15,              
         supra, is conducted using rules similar to those under section               
         301.6343-1(b)(4), Proced. & Admin. Regs., and focuses on the                 
         requesting spouse’s inability to pay reasonable basic living                 
         expenses.  Rev. Proc. 2000-15, sec. 4.02(1)(c).  Section                     
         301.6343-1(b)(4)(ii), Proced. & Admin. Regs., provides that the              
         Commissioner will evaluate a requesting spouse’s claim of                    
         economic hardship by considering any information offered by the              
         requesting spouse that is relevant to the determination,                     
         including, but not limited to, the amount reasonably necessary               
         for basic living expenses and the requesting spouse’s income,                

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