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2000-15 are the same as the marital status element, the economic
hardship element, and the knowledge or reason to know element set
forth in section 4.02(1)(a), (c), and (b), respectively, of that
revenue procedure.
With respect to the marital status positive factor set forth
in section 4.03(1)(a) of Revenue Procedure 2000-15, respondent
concedes that with respect to each of the years at issue that
factor is present in the instant case.
With respect to the economic hardship positive factor and
the knowledge or reason to know positive factor set forth in
section 4.03(1)(b) and (d), respectively, of Revenue Procedure
2000-15, we have found that Ms. Collier has failed to carry her
burden of showing that with respect to each of the years at issue
the economic hardship element and the knowledge or reason to know
element set forth in section 4.02(1)(c) and (b), respectively, of
Revenue Procedure 2000-15 are present in the instant case. On
the instant record, we further find that Ms. Collier has failed
to carry her burden of establishing that with respect to each of
the years at issue the economic hardship positive factor and the
knowledge or reason to know positive factor set forth in section
4.03(1)(b) and (d), respectively, of that revenue procedure are
present in the instant case.
With respect to the abuse positive factor set forth in
section 4.03(1)(c) of Revenue Procedure 2000-15, Ms. Collier
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