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rise to the deficiency; and (4) the taxpayer has not made a good
faith effort to comply with Federal income tax laws in the tax
years following the tax year to which the request for relief
relates. See Ferrarese v. Commissioner, T.C. Memo. 2002-249.
The Commissioner generally does not consider the absence of
factors (1), (2), (3), or (4) in determining whether to grant
relief under section 6015(f). Rev. Proc. 2000-15, sec. 4.03,
2000-1 C.B. at 448-449. However, on the basis of caselaw
deciding whether it was equitable to relieve a taxpayer from
joint liability under former section 6013(e)(1)(D), we consider
the fact that a taxpayer did 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 which, if not true, the Commissioner treats as not
favoring 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
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