- 11 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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