Maureen Monsour - Page 62

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          statement of tax for any of the taxable years 1989, 1991, 1992,             
          and 1993 that is attributable to erroneous items of Mr. Monsour.            
          On the record before us, we find for the reasons set forth in our           
          consideration of petitioner’s position with respect to section              
          6015(b)(1)(B) that petitioner has failed to carry her burden of             
          establishing that the liability for each of the taxable years               
          1989, 1991, 1992, and 1993 for which she seeks relief is solely             
          attributable to Mr. Monsour.  As for the taxable year 1990, on the          
          record before us, we find for similar reasons that petitioner has           
          failed to carry her burden of establishing that the liability for           
          that year for which she seeks relief is solely attributable to Mr.          
          Monsour.                                                                    
               On the record before us, we find that petitioner has failed            
          to carry her burden of establishing that the attribution positive           
          factor set forth in section 4.03(1)(f) of Revenue Procedure 2000-           
          15 is present in this case.                                                 
               Turning to the negative factors weighing against granting              
          relief under section 6015(f) set forth in section 4.03(2) of                
          Revenue Procedure 2000-15, those factors are:                               
                    (a) Attributable to the requesting spouse.  The                   
               unpaid liability or item giving rise to the deficiency                 
               is attributable to the requesting spouse.                              
                    (b) Knowledge, or reason to know.  A requesting                   
               spouse knew or had reason to know of the item giving                   
               rise to a deficiency or that the reported liability                    
               would be unpaid at the time the return was signed.  This               
               is an extremely strong factor weighing against relief.                 
               Nonetheless, when the factors in favor of equitable                    





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