Sandrus L. Collier - Page 37




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          reason to know negative factor, the economic hardship negative              
          factor, and the legal obligation negative factor set forth in               
          section 4.03(2)(b), (d), and (f), respectively, of Revenue                  
          Procedure 2000-15 are the opposites of the knowledge or reason to           
          know positive factor, the economic hardship positive factor, and            
          the legal obligation positive factor set forth in section                   
          4.03(1)(d), (b), and (e), respectively, of that revenue proce-              
          dure.  The attribution negative factor set forth in section                 
          4.03(2)(a) of Revenue Procedure 2000-15 is essentially the                  
          opposite of the attribution positive factor set forth in section            
          4.03(1)(f) of that revenue procedure.28  We have found above 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            
          Revenue Procedure 2000-15 are present in the instant case.  On              
          the instant record, we further find that petitioner has failed to           
          carry her burden of establishing that with respect to each of the           
          years at issue the economic hardship negative factor and the                


               28Although we do not believe that those two factors are                
          exactly opposite because the attribution negative factor does not           
          contain the word “solely” that appears in the attribution posi-             
          tive factor, we conclude that respondent’s use of the word                  
          “solely” in describing the attribution positive factor but not in           
          describing the attribution negative factor does not affect our              
          findings and conclusions with respect to those factors in the               
          instant case.                                                               





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