- 37 - 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.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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