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case. On the instant record, we further find that petitioner has
failed to carry her burden of establishing that the knowledge or
reason to know negative factor and the economic hardship negative
factor set forth in section 4.03(2)(b) and (d), respectively, of
that revenue procedure are not present in the instant case.
With respect to the attribution negative factor set forth in
section 4.03(2)(a) of Revenue Procedure 2000-15, we have found
above that petitioner has failed to carry her burden of estab-
lishing that the unpaid 1993 liability is solely attributable to
Mr. Castle. However, respondent concedes that a significant
portion of that liability is attributable to Mr. Castle. On the
record before us, we find that a significant portion of the
unpaid 1993 liability is not attributable to petitioner.
With respect to the legal obligation negative factor set
forth in section 4.03(2)(f) of Revenue Procedure 2000-15, we have
found above that petitioner has failed to carry her burden of
establishing that Mr. Castle had a legal obligation pursuant to
the property settlement agreement to pay the unpaid 1993 liabil-
ity. However, the property settlement agreement does not estab-
lish that petitioner had a legal obligation to pay that liabil-
ity. On the record before us, we find that petitioner did not
have a legal obligation under the property settlement agreement
to pay the unpaid 1993 liability.
With respect to the negative factor set forth in section
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