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divorce decree or agreement to pay the liability.
(We shall hereinafter refer to the negative factors set forth in
section 4.03(2)(a), (b), (c), (d), (e), and (f) of Revenue
Procedure 2000-15 as the attribution negative factor, the knowl-
edge or reason to know negative factor, the significant benefit
negative factor, the economic hardship negative factor, the
noncompliance negative factor, and the legal obligation negative
factor, respectively.)
The parties do not dispute that the knowledge or 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 procedure. We also
note that the parties do not dispute that the attribution nega-
tive 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.27
27Although we do not believe that those two factors are
exactly opposite because, inter alia, the attribution negative
factor does not contain the word “solely” that appears in the
attribution positive factor, we conclude that respondent’s use of
(continued...)
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