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that the liability would not be paid. In the case of a
liability that arose from a deficiency, the requesting
spouse did not know and had no reason to know of the
items giving rise to the deficiency.
(e) Nonrequesting spouse’s legal obligation. The
nonrequesting spouse has a legal obligation pursuant to
a divorce decree or agreement to pay the outstanding
liability. This will not be a factor weighing in favor
of relief if the requesting spouse knew or had reason to
know, at the time the divorce decree or agreement was
entered into, that the nonrequesting spouse would not
pay the liability.
(f) Attributable to nonrequesting spouse. The
liability for which relief is sought is solely attribut-
able to the nonrequesting spouse.
(We shall hereinafter refer to the positive factors set forth in
section 4.03(1)(a), (b), (c), (d), (e), and (f) of Revenue Proce-
dure 2000-15 as the marital status positive factor, the economic
hardship positive factor, the abuse positive factor, the knowledge
or reason to know positive factor, the legal obligation positive
factor, and the attribution positive factor, respectively.)
With respect to the marital status positive factor set forth
in section 4.03(1)(a) of Revenue Procedure 2000-15, petitioner
does not dispute that that factor is not present in this case.
With respect to the economic hardship positive factor set
forth in section 4.03(1)(b) of Revenue Procedure 2000-15, peti-
tioner contends that that positive factor is present in this case.
That is because, according to petitioner, “She will not be able to
pay bills as due if relief should not be granted.”
In determining whether a requesting spouse will suffer
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