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relief under section 6015(f) set forth in section 4.03(2) of
Revenue Procedure 2000-15, as pertinent here, those factors are:
(a) Attributable to the requesting spouse. The
unpaid liability * * * is attributable to the request-
ing spouse.
(b) Knowledge, or reason to know. A requesting
spouse knew or had reason to know * * * that the re-
ported liability would be unpaid at the time the return
was signed. This is an extremely strong factor weigh-
ing against relief. Nonetheless, when the factors in
favor of equitable relief are unusually strong, it may
be appropriate to grant relief under � 6015(f) in
limited situations where a requesting spouse knew or
had reason to know that the liability would not be paid
* * *.
(c) Significant benefit. The requesting spouse
has significantly benefitted (beyond normal support)
from the unpaid liability * * *.
(d) Lack of economic hardship. The requesting
spouse will not experience economic hardship (within
the meaning of section 4.02(1)(c) of this revenue
procedure) if relief from liability is not granted.
(e) Noncompliance with federal income tax laws.
The requesting spouse has not made a good faith effort
to comply with federal income tax laws in the tax years
following the tax year or years to which the request
for relief relates.
(f) Requesting spouse’s legal obligation. The
requesting spouse has a legal obligation pursuant to a
divorce decree or agreement to pay the liability.
(We shall hereinafter refer to the negative factors set forth in
section 4.03(2)(a), (b), (c), (d), (e), and (f) of Revenue
Procedure 2000-15 as the attribution negative factor, the knowl-
edge or reason to know negative factor, the significant benefit
negative factor, the economic hardship negative factor, the tax
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