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the opposite of the attribution factor in Rev. Proc. 2000-15,
sec. 4.03(1)(f). Consequently, in our review of the
Commissioner’s determination denying relief under section
6015(f), we have held that a finding with respect to the reason
to know, economic hardship, legal obligation, and attribution
factors ordinarily will weigh either in favor of or against
granting equitable relief under section 6015(f). Ewing v.
Commissioner, 122 T.C. 32, 45 (2004). We have also held that a
finding that a requesting spouse did not receive a significant
benefit from the item giving rise to the deficiency weighs in
favor of granting relief under section 6015(f). Id. Finally, we
treat evidence that the remaining positive and negative factors
are not applicable as evidence weighing neither in favor of nor
against granting equitable relief (i.e., as neutral). Id. In
accordance with the above, we shall consider each of the positive
and negative factors enumerated in Rev. Proc. 2000-15, sec. 4.03.
1. Positive Factors
a. Marital Status
Petitioner and Mr. Cowdery divorced in 1997. Respondent
concedes this factor weighs in favor of granting relief.
b. Economic Hardship
For the reasons stated in our analysis of this factor under
Rev. Proc. 2000-15, sec. 4.02, we conclude that petitioner has
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