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relief are unusually strong, it may be appropriate to
grant relief under � 6015(f) in limited situations where
a requesting spouse knew or had reason to know that the
liability would not be paid, and in very limited situa-
tions where the requesting spouse knew or had reason to
know of an item giving rise to a deficiency.
(c) Significant benefit. The requesting spouse has
significantly benefitted (beyond normal support) from
the unpaid liability or items giving rise to the defi-
ciency. See � 1.6013-5(b).
(d) Lack of economic hardship. The requesting
spouse will not experience economic hardship (within the
meaning of section 4.02(1)(c) of this revenue procedure)
if relief from the liability is not granted.
(e) Noncompliance with federal income tax laws.
The requesting spouse has not made a good faith effort
to comply with federal income tax laws in the tax years
following the tax year or years to which the request for
relief relates.
(f) Requesting spouse’s legal obligation. The
requesting spouse has a legal obligation pursuant to a
divorce decree or agreement to pay the liability.
(We shall hereinafter refer to the negative factors set forth in
section 4.03(2)(a), (b), (c), (d), (e), and (f) of Revenue Proce-
dure 2000-15 as the attribution negative factor, the knowledge or
reason to know negative factor, the significant benefit negative
factor, the economic hardship negative factor, the noncompliance
negative factor, and the legal obligation negative factor, respec-
tively.)
The parties do not dispute that the knowledge or reason to
know negative factor, the economic hardship negative factor, and
the legal obligation negative factor set forth in section
4.03(2)(b), (d), and (f), respectively, of Revenue Procedure
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