E. Carolyn Mellen - Page 36




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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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