Maureen Monsour - Page 63

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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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