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not pay the amounts due. Thus, we find that petitioner knew or
had reason to know that the reported liabilities would be unpaid
at the time the returns were filed. This factor weighs against
granting petitioner relief.
4. Nonrequesting spouse’s legal obligation. Mr. Hopkins
did not have a legal obligation pursuant to a divorce decree or
agreement. This factor is neutral.
5. Significant benefit. A significant benefit is a
benefit in excess of normal support. Sec. 1.6015-2(d), Income
Tax Regs. It is unclear how much petitioner benefited from the
unpaid liabilities, but the facts and circumstances suggest that
petitioner did not receive any significant benefit. This factor
is neutral.
6. Compliance with income tax laws. The question is
whether the taxpayer has made a good faith effort to comply with
tax laws in tax years after the years for which relief is
requested. Respondent reviewed petitioner’s account and
determined that petitioner was in compliance for tax years 1997
through 2005. This factor weighs in favor of granting relief.
7. Abuse or poor mental or physical health. In addition
to the foregoing factors, Rev. Proc. 2003-61, sec. 4.03(2)(b)
lists factors that, if present, will weigh in favor of equitable
relief, but, if not present, will not weigh against relief. The
factors are: (1) Whether the nonrequesting spouse abused the
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