- 40 -
issue. 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 significant benefit negative
factor set forth in section 4.03(2)(c) of Revenue Procedure 2000-
15 is not present in the instant case.
With respect to the noncompliance negative factor set forth
in section 4.03(2)(e) of Revenue Procedure 2000-15, Ms. Collier
makes no argument addressing that factor.29 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
noncompliance negative factor is not present in the instant case.
With respect to the legal obligation negative factor set
forth in section 4.03(2)(f) of Revenue Procedure 2000-15, respon-
dent concedes that Mr. Collier has a legal obligation pursuant to
a divorce decree or agreement to pay the outstanding liability
for each of the years at issue. Consequently, respondent con-
cedes that with respect to each of the years at issue the legal
obligation negative factor set forth in section 4.03(2)(f) of
Revenue Procedure 2000-15 is not present in the instant case.
29Although Ms. Collier makes no argument with respect to the
noncompliance negative factor set forth in sec. 4.03(2)(e) of
Revenue Procedure 2000-15, the record establishes that respondent
applied certain of Ms. Collier’s overpayments of tax for taxable
year 1995 and thereafter against the unpaid assessment for
taxable years 1987 and 1988. The record contains no evidence
with respect to the taxable years 1992 through 1994, although it
does establish that after June 22, 1992, Ms. Collier ceased
making installment payments under the 1991 installment agreement.
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