Maureen Monsour - Page 64

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          2000-15 are the opposites of the knowledge or reason to know                
          positive factor, the economic hardship positive factor, and the             
          legal obligation positive factor set forth in section 4.03(1)(d),           
          (b), and (e), respectively, of that revenue procedure.  Nor do              
          the parties dispute that the attribution negative factor set forth          
          in section 4.03(2)(a) of Revenue Procedure 2000-15 is essentially           
          the opposite of the attribution positive factor set forth in                
          section 4.03(1)(f) of that revenue procedure.51                             
               We have found that petitioner has failed to carry her burden           
          of establishing that the economic hardship positive factor and              
          the knowledge or reason to know positive factor set forth in                
          section 4.03(1)(b) and (d), respectively, of Revenue Procedure              
          2000-15 are present in this case.  On the record before us, we              
          find that petitioner has failed to carry her burden of establish-           
          ing that the economic hardship negative factor and the knowledge            
          or reason to know negative factor set forth in section 4.03(2)(d)           
          and (b), respectively, of that revenue procedure are not present            
          in this case.                                                               
               With respect to the attribution negative factor set forth in           
          section 4.03(2)(a) of Revenue Procedure 2000-15, we have found              
          that petitioner has failed to carry her burden of establishing              


               51We do not believe that those two factors are exactly                 
          opposite because the attribution negative factor does not contain           
          the word “solely” that appears in the attribution positive                  
          factor.                                                                     





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