Susan L. Castle - Page 19




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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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