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associated with maintaining those routes. Pursuant to their
divorce decree, petitioner and Mr. Gonce each had obligations to
pay an equal share of their then-outstanding tax liabilities, and
the tax liability was not allocated in the decree to Mr. Gonce
alone. She and Mr. Gonce shared a joint checking account, into
which all of petitioner’s and Mr. Gonce’s paychecks were
deposited. Such benefits did not extend beyond her normal
support. The absence of other benefits weighs in favor of
petitioner. See Ferrarese v. Commissioner, T.C. Memo. 2002-249.
Finally, although petitioner was entitled to a refund in 2002 and
2004, she filed her Federal income tax returns late in those
years. We do not believe this last element weighs either for or
against petitioner.
Rev. Proc. 2003-61, sec. 4.03(2)(b), 2003-2 C.B. at 299,
lists two additional factors that may weigh in favor of equitable
relief under section 6015(f), but that will not weigh against
relief if not present:
(i) * * * Whether the nonrequesting spouse abused
the requesting spouse. The presence of abuse is a
factor favoring relief. A history of abuse by the
nonrequesting spouse may mitigate a requesting spouse’s
knowledge or reason to know.
(ii) * * * Whether the requesting spouse was in
poor mental or physical health on the date the
requesting spouse signed the return or at the time the
requesting spouse requested relief. * * *
Petitioner reported on her Form 12510, Questionnaire for
Requesting Spouse, that she had never been abused by Mr. Gonce
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