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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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