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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), 2000-1 C.B. at 449. 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.
In accordance with the above, we shall consider each of the
positive and negative factors enumerated in Rev. Proc. 2000-15,
sec. 4.03. We shall also consider whether any additional facts
alleged by the parties affect the analysis of whether respondent
abused his discretion in denying petitioner equitable relief
under section 6015(f).
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