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e. Attribution of the Unpaid Item
Respondent concedes that “the full amount at issue is
attributable to Louis Rosenthal.” That factor is favorable. See
Rev. Proc. 2000-15, sec. 4.03(1)(f), (2)(a).
f. Economic Hardship
Because the evidence (which consists entirely of
petitioner’s testimony) shows that petitioner was able to
discharge her customary basic living expenses even after paying
the tax liability arising from the omission of the IRA
distribution from income, there was a lack of “economic hardship”
as that term is defined for purposes of Rev. Proc. 2000-15,
section 4.03(1)(b) and (2)(d). That factor is unfavorable.
g. Knowledge or Reason To Know and Significant Benefit
For the reasons previously discussed herein (section IV. B.
2. and 3.) we find that petitioner had no knowledge or reason to
know of the IRA distribution, and that she did not benefit from
it. Lack of knowledge or reason to know is a favorable factor
(Rev. Proc. 2000-15, section 4.03(1)(d)) and, because lack of
significant benefit is not listed as a favorable factor, it is
considered neutral under Rev. Proc. 2000-15. However, on the
basis of prior caselaw, we consider lack of significant benefit
to be a favorable factor. See Ewing v. Commissioner, 122 T.C. at
45; Foor v. Commissioner, T.C. Memo. 2004-54; Ogonoski v.
Commissioner, T.C. Memo. 2004-52; Ferrarese v. Commissioner,
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