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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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