Phyllis J. Merendino - Page 19

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          view this factor in favor of petitioner.                                    
                         ii.  Economic Hardship                                       
               Our analysis under Rev. Proc. 2000-15, sec. 4.02, concluding           
          that petitioner does not satisfy the economic hardship factor               
          remains applicable here and weighs against petitioner.                      
                         iii.  Abuse by Nonrequesting Spouse                          
               There is no evidence in the record that Dr. Merendino abused           
          petitioner.  Thus, this is a neutral factor.  Ewing v.                      
          Commissioner, 122 T.C. at 46; Washington v. Commissioner, 120               
          T.C. at 149; Rev. Proc. 2000-15, sec. 4.03(1)(c).                           
                         iv.  No Knowledge or Reason To Know                          
               As addressed previously, we are not persuaded that                     
          petitioner lacked knowledge or reason to know that any unpaid tax           
          liability for 1996 would not be paid.  Thus, we find petitioner             
          has failed to carry her burden, and this factor weighs against              
                         v.  Nonrequesting Spouse's Legal Obligation                  
               Because petitioner is not separated or divorced from Dr.               
          Merendino, this is a neutral factor.                                        
                         vi.  Liabilities Solely Attributable to                      
                              Nonrequesting Spouse                                    
               Petitioner seeks relief from paying the amount of tax                  
          liability that is attributable to Dr. Merendino.  Petitioner                
          agrees to pay the tax liability attributable to her income.                 
          Therefore, this factor weighs in favor of petitioner.                       

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