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the proceeds on the sale of the Murrays’ house in mid-1997, and
petitioner and intervenor filed for bankruptcy in September 1997.
We disagree. Intervenor misled petitioner about his intentions
to pay their taxes. Any knowledge about intervenor’s intent to
pay his taxes that petitioner gleaned from her discovery of the
tax liens on the Murrays’ house and their bankruptcy filing
occurred after the Murrays filed the last of the returns for the
years in issue in April 1997.7
e. Conclusion
We conclude that this factor favors petitioner.
7. Whether the Underpayment of Tax Is Attributable to
Intervenor
Respondent concedes that the underpaid tax is solely
attributable to intervenor. This factor favors petitioner.
8. Legal Obligation To Pay Tax
The fact that the nonrequesting spouse has a legal
obligation pursuant to a divorce decree or agreement to pay the
outstanding liability favors granting relief. Rev. Proc. 2000-
15, sec. 4.03, 2000-1 C.B. at 448. In the property settlement
signed in June 1998, intervenor agreed to pay community debts,
which include the taxes from which petitioner seeks relief from
liability.
7 The administrative record does not show that respondent
took the proceeds on the sale of the Murray’s house in mid-1997
before the Murrays filed their 1996 tax return around Apr. 15,
1997.
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