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he was legally obligated to pay under the divorce decree for his
share of the tax liabilities for the years at issue.
Petitioner’s filing for divorce prior to requesting relief
under section 6015(f) favors granting him relief. Rev. Proc.
2000-15, sec. 4.03(1)(a). Yet, even in those cases where the
requesting spouse’s marital status favors granting relief, Rev.
Proc. 2000-15, sec. 4.03(1)(f), 2000-1 C.B. at 449, questions
whether the tax liability is attributable to the spouse
requesting relief. The basis for denying petitioner relief under
section 6015(f) stemmed from respondent’s belief that the
entirety of the tax liabilities for 2000 and 2001 arose from
income earned by petitioner. Petitioner concedes his
responsibility for any tax liability associated with the income
he earned during the years at issue from his employment with the
Art Institute of Seattle. He similarly concedes that the portion
of the underpayment from taxable year 2000 that arose from the
sale of stock was solely his income. The tax liability
associated with the income earned by Ms. Peet for assisting
petitioner with Interactive Arts, his wholly owned Schedule C
business, during the years at issue, however, is the subject of
petitioner’s dispute. At trial, petitioner testified that Ms.
Peet performed design work for Interactive Arts, assisted in
administering the affairs of the business, and received income
from Interactive Arts for these services. Respondent contends
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