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meaning of section 4.02(1)(c) of this revenue proce-
dure) if the Service does not grant relief from the
income tax liability.
(iii) Knowledge or reason to know.
(A) Underpayment cases. In the case of an income
tax liability that was properly reported but not paid,
whether the requesting spouse did not know and had no
reason to know that the nonrequesting spouse would not
pay the income tax liability.
* * * * * * *
(C) Reason to know. For purposes of (A) * * *
above, in determining whether the requesting spouse had
reason to know, the Service will consider the request-
ing spouse’s level of education, any deceit or evasive-
ness of the nonrequesting spouse, the requesting
spouse’s degree of involvement in the activity generat-
ing the income tax liability, the requesting spouse’s
involvement in business and household financial mat-
ters, the requesting spouse’s business or financial
expertise, and any lavish or unusual expenditures
compared with past spending levels.
(iv) Nonrequesting spouse’s legal obligation.
Whether the nonrequesting spouse has a legal obligation
to pay the outstanding income tax liability pursuant to
a divorce decree or agreement. * * *
(v) Significant Benefit. Whether the requesting
spouse received significant benefit (beyond normal
support) from the unpaid income tax liability or item
giving rise to the deficiency. See Treas. Reg.
§1.6015-2(d).
(vi) Compliance with income tax laws. Whether the
requesting spouse has made a good faith effort to
comply with income tax laws in the taxable years fol-
lowing the taxable year or years to which the request
for relief relates.
(We shall hereinafter refer to the factors set forth in section
4.03(2)(a)(i), (ii), (iii), (iv), (v), and (vi) of Revenue
Procedure 2003-61 as the marital status factor, the economic
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Last modified: November 10, 2007