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that the attribution positive factor set forth in section
4.03(1)(f) of that revenue procedure is present in this case. On
the record before us, we find for the reasons set forth in our
consideration of the attribution positive factor that petitioner
has failed to carry her burden of establishing (1) that no item
giving rise to a portion or all of the understatement for each of
the taxable years 1989, 1991, 1992, and 1993 and (2) that no
portion of the unpaid liability for 1990 are attributable to
herself. On the record before us, we find that petitioner has
failed to carry her burden of establishing that the attribution
negative factor set forth in section 4.03(2)(a) of Revenue Proce-
dure 2000-15 is not present in this case.
With respect to the significant benefit negative factor set
forth in section 4.03(2)(c) of Revenue Procedure 2000-15, peti-
tioner makes no argument that that negative factor is not present
with respect to the taxable year 1990. On the record before us,
we find that petitioner has failed to carry her burden of estab-
lishing that she did not significantly benefit beyond normal
support from the unpaid liability with respect to the taxable year
1990.
As for each of the taxable years 1989, 1991, 1992, and 1993,
petitioner argues that
While it may be arguable that the Petitioner benefited
by the reduced taxes and/or omitted income, those argu-
ments appear to be without merit * * * [based on] Peti-
tioner’s own testimony which stated that her lifestyle
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