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law noncompliance negative factor, and the legal obligation
negative factor, respectively.)
We note initially that the parties do not dispute that the
knowledge or reason to know negative factor, the economic hard-
ship negative factor, and the legal obligation negative factor
set forth in section 4.03(2)(b), (d), and (f), respectively, of
Revenue Procedure 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. We also note that the parties do not 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.12
We have found above that petitioner has failed to carry her
burden of establishing that the knowledge or reason to know
positive factor set forth in section 4.03(1)(d) of Revenue
Procedure 2000-15 is present in the instant case and that peti-
12We 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. Nonetheless, we conclude that respondent’s use of the
word “solely” in describing the attribution positive factor but
not in describing the attribution negative factor does not affect
our findings and conclusions in the instant case with respect to
those factors.
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