- 46 - 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.Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47Last modified: November 10, 2007