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includes six factors to be considered. A description of each
factor, underscored, and our evaluation of that factor in this
case, follows.3
(a) Marital status. The requesting spouse is separated or
divorced from the nonrequesting spouse. Petitioner has shown that
she is divorced from Mr. Meadows. This factor weighs in her
favor.
(b) Economic hardship. The requesting spouse will suffer
economic hardship if relief from the liability is not granted.
For reasons explained supra, we do not find that petitioner would
suffer economic hardship if relief were not granted. This factor
weighs against her.
(c) Knowledge or reason to know. 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. We
are unable to determine petitioner’s actual knowledge as to
whether her husband would pay the tax shown on their joint return
for 1999. Indeed, because she signed the return in blank, we are
3In addition to these six factors, the superseded guidelines
included as a factor in sec. 4.03 whether the income tax
liability was attributable to an item of the nonrequesting
spouse. As explained supra note 1, this factor is a threshold
requirement found in sec. 4.01 of the modified guidelines. In
addition, the superseded guidelines included spousal abuse as a
factor to be considered in sec. 4.03. That factor is part of the
threshold considerations of sec. 4.01 in the modified guidelines;
the parties agree that there was no such abuse in this case.
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