- 21 - essentially the opposite of the attribution factor in Rev. Proc. 2000-15, sec. 4.03(1)(f), a. Positive Factors i. Marital Status Petitioner does not claim that this factor favors her position. Nor do we find that such is the case. Petitioner is neither separated nor divorced from Albin. We hold that this factor does not weigh in favor of granting equitable relief to petitioner for any of the subject years. Because Rev. Proc. 2000-15, supra, states that this factor will only serve to weigh in favor of granting relief when it is met, and fails to state that this factor will weigh against granting relief when it is not met, we consider this factor neutral. ii. Economic Hardship Petitioner argues that she will suffer economic hardship if equitable relief is not granted to her for each of the subject years. Petitioner argues that a decision adverse to her in this case will force her to sell all of her assets so that she may pay the liabilities in issue and may even result in her incurring a new liability for taxes due on any capital gain that she realizes on the sale. In determining whether a requesting spouse will suffer economic hardship, Rev. Proc. 2000-15, sec. 4.02(1)(c), to which Rev. Proc. 2000-15, sec. 4.03(1)(b), refers, requires reliance onPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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