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With respect to the marital status positive factor set forth
in section 4.03(1)(a) of Revenue Procedure 2000-15, respondent
concedes that that factor is present here.
With respect to the economic hardship positive factor and
the knowledge or reason to know positive factor set forth in
section 4.03(1)(b) and (d), respectively, of Revenue Procedure
2000-15, we have found that petitioner has failed to carry her
burden of showing that the economic hardship element and the
knowledge or reason to know element set forth in section
4.02(1)(c) and (b), respectively, of Revenue Procedure 2000-15
are present here. On the instant record, we further find that
petitioner has failed to carry her burden of establishing that
the economic hardship positive factor and the knowledge or reason
to know positive factor set forth in section 4.03(1)(b) and (d),
respectively, of that revenue procedure are present here.
With respect to the abuse positive factor set forth in
section 4.03(1)(c) of Revenue Procedure 2000-15, petitioner
relies on the five incident reports prepared by officers of the
Haverford police department between December 18, 1999, and
February 11, 2001, and on her testimony to support her position
that the abuse positive factor is present here. According to
petitioner,
during the taxable year at issue and, both before and
afterwards, the Intervenor abused drugs and alcohol,
which resulted in aberrant behavior and his abusive
treatment of her. Petitioner credibly testified that,
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