- 38 - knowledge or reason to know negative factor set forth in section 4.03(2)(d) and (b), respectively, of that revenue procedure are not present in the instant case. With respect to the attribution negative factor set forth in section 4.03(2)(a) of Revenue Procedure 2000-15, we have found above 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. Ms. Collier prof- fered no reliable evidence to show that no portion of the unpaid liability for each of the years at issue is attributable to her. 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 negative factor set forth in section 4.03(2)(a) of Revenue Procedure 2000-15 is not present in the instant case. With respect to the significant benefit negative factor set forth in section 4.03(2)(c) of Revenue Procedure 2000-15, Ms. Collier contends on brief that she did not significantly benefit from the unpaid assessment for each of the years at issue be- cause, inter alia: [Mr. Collier] failed to support petitioner and their son adequately, resulting in her having to borrow money from friends on occasion. Moreover, there were times that petitioner could not even pay the household bills at times due to her husband’s controlling of the fam- ily’s money. [Internal references omitted.]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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