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With respect to the attribution negative factor set forth in
section 4.03(2)(a) of Revenue Procedure 2000-15, we found above
that petitioner carried her burden of establishing that the
attribution positive factor set forth in section 4.03(1)(f) of
that revenue procedure is present in the instant case. On the
record before us, we further find that petitioner has carried her
burden of establishing that 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 knowledge or reason to know negative
factor set forth in section 4.03(2)(b) of Revenue Procedure 2000-
15, we indicated above that petitioner does not dispute that the
knowledge or reason to know positive factor set forth in section
4.03(1)(d) of that revenue procedure is not present in the
instant case. Nor does petitioner dispute that the knowledge or
reason to know negative factor set forth in section 4.03(2)(b) of
that revenue procedure is present in the instant case. Instead,
petitioner contends, as she does with respect to the knowledge or
reason to know positive factor, that the knowledge or reason to
know negative factor is “legally irrelevant” to resolving whether
petitioner is entitled to relief under section 6015(f). We found
27(...continued)
the word “solely” in describing the attribution positive factor
but not in describing the attribution negative factor does not
affect our findings and conclusions with respect to those factors
in the instant case.
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