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(1) that the five incident reports prepared by officers of the
Haverford police department would have reflected petitioner’s
claims of such alleged drug and alcohol abuse and such alleged
aberrant behavior and abusive treatment and (2) that petitioner
would have made complaints to the Haverford police department
alleging such matters well before she made her first complaint on
December 18, 1999.
On the record before us, we find that petitioner has failed
to carry her burden of showing that the abuse positive factor set
forth in section 4.03(1)(c) of Revenue Procedure 2000-15 is
present here.
With respect to the legal obligation positive factor set
forth in section 4.03(1)(e) of Revenue Procedure 2000-15, peti-
tioner concedes that as of the time of the trial in this case
there was no legal obligation for Mr. Krasner to pay any tax due
for taxable year 1998. Respondent concedes that as of that time
there was no legal obligation for petitioner to pay any tax due
for that year.31 On the record before us, we find that the legal
obligation positive factor is a neutral factor in this case.
With respect to the attribution positive factor set forth in
section 4.03(1)(f) of Revenue Procedure 2000-15, respondent
concedes that the unpaid 1998 liability is solely attributable to
31As of the time of the trial in this case, there was no
final divorce decree or agreement in which a court addressed who
was to pay any tax due for taxable year 1998. See infra note 33.
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