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know negative factor, the economic hardship negative factor, and
the legal obligation negative factor, respectively.)
We note initially that the parties do not dispute that the
knowledge or reason to know negative factor, the economic hard-
ship negative factor, and the legal obligation negative factor
set forth in section 4.03(2)(b), (d), and (f), respectively, of
Revenue Procedure 2000-15 are the opposites of the knowledge or
reason to know positive factor, the economic hardship positive
factor, and the legal obligation positive factor set forth in
section 4.03(1)(d), (b), and (e), respectively, of that revenue
procedure. We also note that the parties do not dispute that the
attribution negative factor set forth in section 4.03(2)(a) of
Revenue Procedure 2000-15 is essentially the opposite of the
attribution positive factor set forth in section 4.03(1)(f) of
that revenue procedure.10 We have found above that petitioner
has failed to carry her burden of establishing that the knowledge
or reason to know positive factor and the economic hardship
positive factor set forth in section 4.03(1)(d) and (b), respec-
tively, of Revenue Procedure 2000-15 are present in the instant
10Although we do not believe that those two factors are
exactly opposite because the attribution negative factor does not
contain the word “solely” that appears in the attribution posi-
tive factor, we conclude that respondent’s use of the word
“solely” in describing the attribution positive factor but not in
describing the attribution negative factor does not affect our
findings and conclusions with respect to those factors in the
instant case.
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