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tax.”25
The record establishes the amount of tax withheld from the
respective wages of Ms. Collier and Mr. Collier for only two of
the taxable years at issue, i.e., 1989 and 1990. The record does
not establish the tax withheld from either Ms. Collier’s wages or
Mr. Collier’s wages for taxable years 1988 and 1991.26 On the
instant record, we find that Ms. Collier has failed to carry her
burden of showing that the unpaid liability for each of the years
at issue is solely attributable to Mr. Collier’s allegedly having
claimed an excessive number of withholding allowances.
On the record before us, we find that Ms. Collier has failed
to carry her burden of establishing that with respect to each of
the years at issue the attribution positive factor set forth in
section 4.03(1)(f) of Revenue Procedure 2000-15 is present in the
instant case.
Turning to the negative factors set forth in section 4.03(2)
of Revenue Procedure 2000-15 that weigh against relief,27 Ms.
25Assuming arguendo that Mr. Collier had claimed 10 to 12
withholding allowances for each of the taxable years at issue,
the record does not disclose whether or not Mr. Collier would
have had a valid reason for claiming such number of allowances.
26For taxable years 1988 and 1991, the record establishes
only the total tax withheld from the wages of Ms. Collier and Mr.
Collier.
27As pertinent here, sec. 4.03(2) of Revenue Procedure 2000-
15 provides:
(continued...)
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