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tioner concedes that the economic hardship positive factor set
forth in section 4.03(1)(b) of that revenue procedure is not
present in the instant case. On the instant record, we further
find that petitioner has failed to carry her burden of establish-
ing that the knowledge or reason to know negative factor set
forth in section 4.03(2)(b) of Revenue Procedure 2000-15 is not
present in the instant case and that petitioner concedes that the
economic hardship negative factor set forth in section 4.03(2)(d)
of that revenue procedure is present in the instant case.
With respect to the attribution negative factor set forth in
section 4.03(2)(a) of Revenue Procedure 2000-15, we have found
that petitioner concedes that the unpaid 1998 liability is not
solely attributable to Mr. Simon. Respondent concedes that a
significant portion (approximately 84 percent) of that liability
is attributable to Mr. Simon. On the record before us, we find
that a significant portion of the liability for taxable year 1998
is not attributable to petitioner.
With respect to the significant benefit negative factor set
forth in section 4.03(2)(c) of Revenue Procedure 2000-15, respon-
dent does not dispute that that factor is not present in the
instant case.
With respect to the tax law noncompliance negative factor
set forth in section 4.03(2)(e) of Revenue Procedure 2000-15,
respondent does not dispute that that factor is not present in
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