- 14 - liability. This will not be a factor weighing in favor of relief if the requesting spouse knew or had reason to know, at the time the divorce decree or agreement was entered into, that the nonrequesting spouse would not pay the liability. (f) Attributable to nonrequesting spouse. The liability for which relief is sought is solely attrib- utable to the nonrequesting spouse. (We shall hereinafter refer to the positive factors set forth in section 4.03(1)(a), (b), (d), (e), and (f) of Revenue Procedure 2000-15 as the marital status positive factor, the economic hardship positive factor, the knowledge or reason to know posi- tive factor, the legal obligation positive factor, and the attribution positive factor, respectively.) We note initially that the parties do not dispute that the marital status positive factor, the knowledge or reason to know positive factor, and the economic hardship positive factor set forth in section 4.03(1)(a), (d), and (b), respectively, of Revenue Procedure 2000-15 are the same as the marital status element, the knowledge or reason to know element, and the eco- nomic hardship element set forth in section 4.02(1)(a), (b), and (c), respectively, of that revenue procedure. With respect to the marital status positive factor set forth in section 4.03(1)(a) of Revenue Procedure 2000-15, respondent concedes that that factor is present in the instant case. With respect to the economic hardship positive factor and the knowledge or reason to know positive factor set forth inPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011