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4.02(1)(a), (b), and (c) of Revenue Procedure 2000-15 as the
marital status element, the knowledge or reason to know element,
and the economic hardship element, respectively.)
Section 4.02(2) of Revenue Procedure 2000-15 provides that
relief granted under section 4.02(1) of that revenue procedure is
subject to the following limitations:
(a) If the return is or has been adjusted to
reflect an understatement of tax, relief will be avail-
able only to the extent of the liability shown on the
return prior to any such adjustment; and
(b) Relief will only be available to the
extent that the unpaid liability is allocable to the
nonrequesting spouse.
Turning to the three elements set forth in section 4.02(1)
of Revenue Procedure 2000-15, the presence of which will ordi-
narily result in a grant of relief under section 6015(f), respon-
dent concedes that with respect to each of the years at issue the
marital status element is present in the instant case.
With respect to the knowledge or reason to know element set
forth in section 4.02(1)(b) of Revenue Procedure 2000-15, Ms.
Collier contends that that element is present here. In order for
the knowledge or reason to know element to be present in the
instant case, Ms. Collier must establish (1) that at the time the
joint return for each of the years at issue was signed she had no
knowledge or reason to know that the tax reported in each of
those returns would not be paid and (2) that it was reasonable
for her to believe that Mr. Collier would pay the reported tax
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