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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 on
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