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not significantly benefit from the unpaid liability as favoring
equitable relief for that taxpayer. See Belk v. Commissioner, 93
T.C. 434, 440-441 (1989); Ferrarese v. Commissioner, supra; Foley
v. Commissioner, T.C. Memo. 1995-16; Robinson v. Commissioner,
T.C. Memo. 1994-557; Klimenko v. Commissioner, T.C. Memo. 1993-
340; Hillman v. Commissioner, T.C. Memo. 1993-151.
Rev. Proc. 2000-15, sec. 4.03, lists the following four
factors which, if true, the Commissioner treats as favoring
relief, and if not true, as weighing against relief: (5) The
taxpayer would suffer economic hardship if relief were denied;
(6) in the case of a liability that was properly reported but not
paid, the taxpayer did not know and had no reason to know that
the liability would not be paid; (7) the liability for which
relief is sought is attributable to the nonrequesting spouse; and
(8) the nonrequesting spouse has a legal obligation pursuant to a
divorce decree or agreement to pay the outstanding liability
(weighs against relief only if the requesting spouse has the
obligation). Rev. Proc. 2000-15, sec. 4.03, also states that no
single factor is controlling, all factors will be considered and
weighed appropriately, and the list of factors in Rev. Proc.
2000-15, sec. 4, is not exhaustive.
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