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record presented that petitioner did not significantly benefit
beyond normal support from the unpaid 1998 liability. On the
record before us, we find that petitioner has failed to carry her
burden of establishing that she did not significantly benefit
beyond normal support from that unpaid liability.
On the record before us, we find that petitioner has failed
to carry her burden of establishing that the significant benefit
negative factor set forth in section 4.03(2)(c) of Revenue
Procedure 2000-15 is not present here.
With respect to the tax law noncompliance negative factor
set forth in section 4.03(2)(e) of Revenue Procedure 2000-15,
respondent concedes that that factor is not present here.
With respect to the legal obligation negative factor set
forth in section 4.03(2)(f) of Revenue Procedure 2000-15, as
discussed above, respondent concedes that as of the time of the
trial in this case there was no legal obligation for petitioner
to pay any tax due for taxable year 1998, and petitioner concedes
that at that time there was no legal obligation for Mr. Krasner
to pay any tax due for that year.33 As a result, we have found
that the legal obligation positive factor set forth in section
4.03(1)(e) of Revenue Procedure 2000-15 is a neutral factor in
this case. On the record before us, we find that the legal
obligation negative factor set forth in section 4.03(2)(f) of
33See supra note 31.
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