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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
divorce decree or agreement to pay the liability.
The knowledge or reason to know factor, the economic hardship
factor, and the legal obligation factor in Rev. Proc. 2000-15,
sec. 4.03(2)(b), (d), and (f), respectively, are the opposites of
the knowledge or reason to know factor, the economic hardship
factor, and the legal obligation factor in Rev. Proc. 2000-15,
sec. 4.03(1)(d), (b), and (e), respectively. The attribution
factor in Rev. Proc. 2000-15, sec. 4.03(2)(a) is substantially
the opposite of the attribution factor in Rev. Proc. 2000-15,
sec. 4.03(1)(f). Consequently, in our review of the
Commissioner’s determination denying relief under section
6015(f), we have held that a finding with respect to the reason
to know, economic hardship, legal obligation, and attribution
factors ordinarily will weigh either in favor of or against
granting equitable relief under section 6015(f). Ewing v.
Commissioner, 122 T.C. 32, 45 (2004). We have also held that a
finding that a requesting spouse did not receive a significant
benefit from the item giving rise to the deficiency weighs in
favor of granting relief under section 6015(f). Id. Finally, we
treat evidence that the remaining positive and negative factors
are not applicable as evidence weighing neither in favor of nor
against granting equitable relief (i.e., as neutral). Id.
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