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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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