Janet H. Krasner, Petitioner, and Paul Krasner , Intervenor - Page 60

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          Mr. Krasner.  We find that respondent concedes that the attribu-            
          tion positive factor is present here.                                       
               Turning to the negative factors weighing against granting              
          relief under section 6015(f) set forth in section 4.03(2) of                
          Revenue Procedure 2000-15, as pertinent here, those factors are:            
                    (a) Attributable to the requesting spouse.  The                   
               unpaid liability * * * is attributable to the request-                 
               ing spouse.                                                            
                    (b) Knowledge, or reason to know.  A requesting                   
               spouse knew or had reason to know * * * that the re-                   
               ported liability would be unpaid at the time the return                
               was signed.  This is an extremely strong factor weigh-                 
               ing against relief.  Nonetheless, when the factors in                  
               favor of equitable relief are unusually strong, it may                 
               be appropriate to grant relief under � 6015(f) in                      
               limited situations where a requesting spouse knew or                   
               had reason to know that the liability would not be paid                
               * * *.                                                                 
                    (c) Significant benefit.  The requesting spouse                   
               has significantly benefitted (beyond normal support)                   
               from the unpaid liability * * *.                                       
                    (d) Lack of economic hardship.  The requesting                    
               spouse will not experience economic hardship (within                   
               the meaning of section 4.02(1)(c) of this revenue                      
               procedure) if relief from liability is not granted.                    
                    (e) Noncompliance with federal income tax laws.                   
               The requesting spouse has not made a good faith effort                 
               to comply with federal income tax laws in the tax years                
               following the tax year or years to which the request                   
               for relief relates.                                                    
                    (f) Requesting spouse’s legal obligation.  The                    
               requesting spouse has a legal obligation pursuant to a                 
               divorce decree or agreement to pay the liability.                      
          (We shall hereinafter refer to the negative factors set forth in            
          section 4.03(2)(a), (b), (c), (d), (e), and (f) of Revenue                  






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