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that all factors are to be considered and weighed appropriately,
and that the list of factors is not intended to be exhaustive.
The knowledge or reason to know factor, the economic
hardship factor, and the legal obligation to pay factor in Rev.
Proc. 2000-15, sec. 4.03(2)(b), (d), and (f), 2000-1 C.B. at 449,
respectively, are the opposites of the knowledge or reason to
know factor, the economic hardship factor, and the legal
obligation to pay factor in Rev. Proc. 2000-15, sec. 4.03(1)(d),
(b), and (e), respectively. The attribution factor in Rev. Proc.
2000-15, sec. 4.03(2)(a) is substantially the opposite of the
attribution factor in Rev. Proc. 2000-15, sec. 4.03(1)(f).
Consequently, in the Court’s review of the Commissioner's
determination denying relief under section 6015(f), the Court has
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. at
45. The Court has 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, the Court treats evidence that
the remaining positive and negative factors are not applicable as
evidence weighing neither in favor of nor against granting
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Last modified: May 25, 2011