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liabilities would not be paid at the respective times she signed
the 1998, 1999, and 2000 joint returns--especially because
knowledge or reason to know that a tax would be unpaid is “an
extremely strong factor weighing against relief.” Rev. Proc.
2000-15, sec. 4.03(2)(b), 2000-1 C.B. at 449. We are also
mindful of petitioner’s failure to demonstrate that she would
suffer economic hardship if relief were not granted, and that
the tax balances due for the years in issue are partly
attributable to late filing and failure to pay additions to tax
and related interest and, for taxable year 2000, petitioner’s
$20,000 distribution from her IRA.
On the basis of the facts and circumstances presented, we
find that it would not be inequitable to hold petitioner liable
for the outstanding liabilities for taxable years 1998, 1999,
and 2000. We, therefore, conclude that petitioner is not
entitled to equitable relief from joint and several liability
under section 6015(f). In reaching this conclusion, we have
considered all arguments made by the parties and, to the extent
not mentioned above, we conclude that they are irrelevant or
without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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