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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.]
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