Susan L. Castle - Page 14




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               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 in                






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