- 38 - found in Rev. Proc. 2003-61, 2003-2 C.B. 296. We review respondent’s denial of relief under section 6015(f) for abuse of discretion. See Alt v. Commissioner, 119 T.C. at 315-316. Rev. Proc. 2003-61, sec. 4.01, 2003-2 C.B. at 297, provides seven threshold conditions to determine relief. Respondent concedes that Mrs. Dunne satisfies these conditions. Mrs. Dunne mistakenly argues that she is entitled to relief by satisfying these threshold conditions alone. On the contrary, after a taxpayer satisfies the threshold requirements, Rev. Proc. 2003- 61, sec. 4.03, 2003-2 C.B. at 298, provides the Commissioner a nonexclusive list of factors that the Commissioner uses in determining whether the individual is entitled to relief on the basis of all the facts and circumstances in the case. The relevant factors to be considered here are marital status, economic hardship, knowledge or reason to know, significant benefit, and compliance with the income tax laws. The fact that petitioners have been married and living together at all relevant times is neutral. The economic hardship factor also weighs against Mrs. Dunne. Mrs. Dunne’s only argument regarding this factor is that the amount of tax due is large. However, Mrs. Dunne has not provided any evidence that (1) she will suffer economic hardship if we do not grant her relief, (2) she does not have sufficient assets toPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 NextLast modified: March 27, 2008