Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor - Page 11

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          liability for which relief is sought is attributable to the                 
          nonrequesting spouse; and (8) the nonrequesting spouse has a                
          legal obligation pursuant to a divorce decree or agreement to pay           
          the outstanding liability (weighs against relief only if the                
          requesting spouse has the obligation).  Rev. Proc. 2000-15, sec.            
          4.03, also states that no single factor is controlling, all                 
          factors will be considered and weighed appropriately, and the               
          list of factors in Rev. Proc. 2000-15, sec. 4, is not exhaustive.           
               For reasons discussed next, we conclude that none of the               
          factors listed in Rev. Proc. 2000-15, supra, supports                       
          respondent’s determination in this case, and additional factors             
          discussed below favor relief.                                               
          C.   Application of the Factors Listed in Rev. Proc. 2000-15                
               1.   Petitioner’s Marital Status                                       
               Petitioner was divorced from intervenor when she sought                
          relief.  This factor favors petitioner.                                     
               2.   Spousal Abuse                                                     
               Petitioner testified that there was no abuse in her former             
          marriage.  Respondent determined that this factor is neutral.  We           
          agree with respondent’s determination on this point.                        
               3.   Significant Benefit                                               
               Respondent concedes that petitioner did not significantly              
          benefit from intervenor’s underpayment of tax for 1992 through              
          1996.  This factor favors petitioner.  See Belk v. Commissioner,            






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