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section 4.03(1)(b) and (d), respectively, of Revenue Procedure
2000-15, we have found above that petitioner has failed to carry
her burden of establishing that the economic hardship element and
the knowledge or reason to know element set forth in section
4.02(1)(c) and (b), respectively, of that revenue procedure are
present in the instant case. On the instant record, we further
find that petitioner has failed to carry her burden of establish-
ing that those same positive factors are present for purposes of
section 4.03(1) of Revenue Procedure 2000-15.
With respect to the positive factor set forth in section
4.03(1)(c) of Revenue Procedure 2000-15 (i.e., the requesting
spouse was abused by the nonrequesting spouse), petitioner does
not allege, and the record does not establish, any abuse by Mr.
Castle.
With respect to the legal obligation positive factor set
forth in section 4.03(1)(e) of Revenue Procedure 2000-15, peti-
tioner contends that that factor is present in the instant case
because Mr. Castle had a legal obligation to pay the unpaid 1993
liability. In support of that contention, petitioner asserts:
“In accordance with the terms of the Property Settlement Agree-
ment, * * * Roger L. Castle agreed to assume and pay debts
holding Petitioner harmless from all financial and tax obliga-
tions enumerated therein, which included debt to the Internal
Revenue Service.” The property settlement agreement on which
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