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is attributable to the requesting spouse.
(b) Knowledge, or reason to know. A requesting
spouse knew or had reason to know of the item giving
rise to a deficiency or that the reported liability
would be unpaid at the time the return was signed.
This is an extremely strong factor weighing against
relief. * * *
(c) Significant benefit. The requesting spouse
has significantly benefitted (beyond normal support)
from the unpaid liability or items giving rise to the
deficiency. * * *
(d) Lack of economic hardship. The requesting
spouse will not experience economic hardship (within
the meaning of section 4.02(1)(c) of this revenue
procedure) if relief from the liability is not granted.
(e) Noncompliance with federal income tax laws.
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 or years to which the request
for relief relates.
(f) Requesting spouse's legal obligation. The
requesting spouse has a legal obligation pursuant to a
divorce decree or agreement to pay the liability.
The above guidelines are not intended to be exhaustive, and no
single factor is determinative whether equitable relief will be
granted in a particular case. Rather, all factors will be
considered and weighed appropriately. Ewing v. Commissioner, 122
T.C. 32, 48 (2004); Rev. Proc. 2000-15, sec. 4.03.
A. Positive Factors
i. Marital Status
Petitioner and Dr. Merendino lived apart since at least
1998, with a few exceptions that disqualified petitioner under
the previous section 4.02(1)(a). Given the overall record, we
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