Maureen Monsour - Page 54

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          find that petitioner has failed to carry her burden of establish-           
          ing that the economic hardship positive factor set forth in                 
          section 4.03(1)(b) of Revenue Procedure 2000-15 is present in this          
          case.                                                                       
               With respect to the abuse positive factor set forth in                 
          section 4.03(1)(c) of Revenue Procedure 2000-15, petitioner does            
          not dispute that that positive factor is not present in this case.          
               With respect to the knowledge or reason to know positive               
          factor set forth in section 4.03(1)(d) of Revenue Procedure                 
          2000-15, petitioner makes no argument that that positive factor is          
          present with respect to the taxable year 1990.  On the record               
          before us, we find that petitioner has failed to carry her burden           
          of establishing that she did not know, and had no reason to know,           
          that the liability reported in the original 1990 joint return               
          would not be paid.                                                          
               As for each of the taxable years 1989, 1991, 1992, and 1993,           
          petitioner argues that the knowledge or reason to know positive             
          factor is present with respect to each such year.  The parties do           
          not dispute that the types of facts and circumstances that the              
          Court should consider in determining whether a requesting spouse            
          has established that the knowledge or reason to know positive               
          factor is present are the same types of facts and circumstances             
          that the Court has considered in determining whether a requesting           
          spouse has satisfied section 6015(b)(1)(C).  Indeed, in holding             






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