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set forth in section 4.03(1)(b) of Revenue Procedure 2000-15 and
the knowledge or reason to know positive factor set forth in
section 4.03(1)(d) of that revenue procedure are present here.
On the instant record, we further find that petitioner has failed
to carry her burden of establishing that the knowledge or reason
to know negative factor set forth in section 4.03(2)(b) of
Revenue Procedure 2000-15 and the economic hardship negative
factor set forth in section 4.03(2)(d) of that revenue procedure
are not present here.
With respect to the attribution negative factor set forth in
section 4.03(2)(a) of Revenue Procedure 2000-15, we have found
that respondent concedes that the attribution positive factor is
present in this case. On the record before us, we find that
respondent concedes that the attribution negative factor set
forth in section 4.03(2)(a) of Revenue Procedure 2000-15 is not
present here.
With respect to the significant benefit negative factor set
forth in section 4.03(2)(c) of Revenue Procedure 2000-15 (i.e.,
whether the requesting spouse has significantly benefited beyond
normal support from the unpaid liability), it is petitioner’s
position that she “did not significantly benefit from the nonpay-
ment of taxes.” In support of her position, petitioner asserts
that “she had neither knowledge nor reason to know of the nonpay-
ment because of Intervenor’s own lavish spending on gifts” and
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