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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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