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pay this liability, or (3) the burden of paying this liability
will fall on her instead of Mr. Dunne.
The knowledge factor weighs in favor of Mrs. Dunne. As we
stated in our discussion of section 6015(b)(1)(C), given the
circumstances of this case, Mrs. Dunne had no reason to know that
Mr. Dunne held beneficial ownership of FRC through May 8, 1997,
and she satisfied her duty of inquiry.
As discussed above, Mrs. Dunne presumably received some
benefit from Mr. Dunne’s status as a shareholder during 1997
because she shared bank accounts with Mr. Dunne, most likely had
access to the dividends he received from FRC, and benefited as he
did from avoiding tax on his share of its income. This factor
weighs against Mrs. Dunne. See Richardson v. Commissioner,
supra.
The compliance with the income tax law factor weighs
slightly against Mrs. Dunne. Mrs. Dunne testified that the one
thing she knows about the tax law is that income tax returns are
due on April 15, yet as discussed below she failed to file her
1999 tax return on time without any reasonable cause.
Mrs. Dunne has not argued that there are any other factors
that we should consider. We find on the basis of all the facts
and circumstances Mrs. Dunne has failed to carry her burden and
thus is not entitled to equitable relief under section 6015(f),
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