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marital status element, the knowledge or reason to know element,
and the economic hardship element, respectively.)
Section 4.02(2) of Revenue Procedure 2000-15 provides that
relief granted under section 4.02(1) of that revenue procedure is
subject to the following limitations:
(a) If the return is or has been adjusted to
reflect an understatement of tax, relief will be avail-
able only to the extent of the liability shown on the
return prior to any such adjustment; and
(b) Relief will only be available to the extent
that the unpaid liability is allocable to the
nonrequesting spouse.
Turning to the three elements set forth in section 4.02(1)
of Revenue Procedure 2000-15, the presence of which will ordi-
narily result in a grant of relief under section 6015(f), in the
instant case, (1) respondent concedes that the marital status
element is present, (2) the parties dispute whether the knowledge
or reason to know element is present, and (3) the parties dispute
whether the economic hardship element is present.
With respect to the knowledge or reason to know element,
petitioner contends that that element is present here. In order
for the knowledge or reason to know element to be present in the
instant case, petitioner must establish (1) that at the time the
1998 joint return was signed she had no knowledge or reason to
know that the tax shown due in that return would not be paid and
(2) that it was reasonable for her to believe that Mr. Krasner
would pay such tax.
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