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4.03(2)(c) of Revenue Procedure 2000-15 (i.e., the requesting
spouse has significantly benefited from the unpaid liability),
petitioner contends that that factor is not present in this case
because she “received no significant assets or support from Mr.
Castle.” In support of that contention, petitioner asserts that
when she divorced Mr. Castle “She left with her and her son’s
personal belongings and clothing.” The terms of the property
settlement agreement do not contradict that assertion. However,
petitioner and Mr. Castle signed that agreement approximately 5
years after the taxable year at issue and 2 years after they
filed the 1993 joint return. We conclude that petitioner’s
assertion that when she divorced Mr. Castle she took from her
marriage to him only “her and her son’s personal belongings and
clothing” is not determinative of whether she significantly
benefited from the unpaid 1993 liability. Petitioner did not
proffer any other evidence to show that she did not significantly
benefit from the unpaid 1993 liability. On the record before us,
we find that petitioner has failed to carry her burden of estab-
lishing that the negative factor set forth in section 4.03(2)(c)
of Revenue Procedure 2000-15 is not present in the instant case.
With respect to the negative factor set forth in section
4.03(2)(e) of Revenue Procedure 2000-15 (i.e., the requesting
spouse has not made a good faith effort to comply with the tax
laws in the taxable years following the year to which the request
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