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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. See � 1.6013-5(b).
(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
divorce decree or agreement to pay the liability.
These positive and negative factors are not exhaustive, and none
of them is decisive in and of itself. All factors must be
considered and weighed appropriately. Id.
We proceed to consider the 12 listed factors seriatim and
then to consider whether any unlisted factor is also applicable
to this case. Neither party disputes that 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. Nor does either party dispute that
the attribution factor in Rev. Proc. 2000-15, sec. 4.03(2)(a), is
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