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15, 1994 accident in which Mr. Mellen’s property was damaged or
destroyed. On the record before us, we find that petitioner has
carried her burden of establishing that the attribution positive
factor set forth in section 4.03(1)(f) of Revenue Procedure 2000-
15 is present in the instant case.
Turning to the negative factors weighing against granting
relief under section 6015(f) set forth in section 4.03(2) of
Revenue Procedure 2000-15, as pertinent here, those factors are:
(a) Attributable to the requesting spouse. The
unpaid liability or item giving rise to the deficiency
is attributable to the requesting spouse.
(b) Knowledge, or reason to know. A requesting
spouse knew or had reason to know of the item giving
rise to a deficiency * * *. This is an extremely
strong factor weighing against relief. Nonetheless,
when the factors in favor of equitable relief are
unusually strong, it may be appropriate to grant relief
under � 6015(f) * * * in very limited situations where
the requesting spouse knew or had reason to know of an
item giving rise to a deficiency.
(c) Significant benefit. The requesting spouse
has significantly benefitted (beyond normal support)
from the unpaid liability or items giving rise to the
deficiency. * * *
(d) Lack of economic hardship. The requesting
spouse will not experience economic hardship (within
the meaning of section 4.02(1)(c) of this revenue
procedure) if relief from the liability is not granted.
(e) Noncompliance with federal income tax laws.
The requesting spouse has not made a good faith effort
to comply with federal income tax laws in the tax years
following the tax year or years to which the request
for relief relates.
(f) Requesting spouse’s legal obligation. The
requesting spouse has a legal obligation pursuant to a
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