Vernon Stacy Taylor - Page 9

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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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