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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.
vi. Attributable to Nonrequesting Spouse
The liabilities for which relief is sought are attributable
solely to the nonrequesting spouse, Albin, and respondent
concedes as much. We hold that this factor weighs in favor of
granting equitable relief to petitioner for each of the subject
years.
b. Negative Factors
i. Attributable to the Requesting Spouse
As stated above, none of the understatements is attributable
to petitioner. We hold that this factor does not weigh against
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 against granting relief when it
is met, and fails to state that this factor will weigh in favor
of granting relief when it is not met, we consider this factor
neutral.
ii. Knowledge or Reason To Know
For the reasons stated above in our analysis of the positive
counterpart to this factor, we conclude that petitioner had
reason to know about the understatements and shelter deductions
in issue at all relevant times. We hold that this factor weighs
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