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448-449, contains a list of positive and negative factors that
the Commissioner must take into account in determining, on the
facts and circumstances, whether to grant full or partial
equitable relief under section 6015(f). As Rev. Proc. 2000-15,
sec. 4.03 makes clear, no single factor is determinative in any
particular case, all factors are to be considered and weighed
appropriately, and the listing of factors is not intended to be
exhaustive. See also Washington v. Commissioner, supra at 148;
Jonson v. Commissioner, supra at 125.
Rev. Proc. 2000-15, sec. 4.03(1) lists the following six
positive factors that the Commissioner will weigh in favor of
granting equitable relief:
(a) Marital status. The requesting spouse is
separated * * * or divorced from the nonrequesting
spouse.
(b) Economic hardship. The requesting spouse
would suffer economic hardship (within the meaning of
section 4.02(1)(c) of this revenue procedure) if relief
from the liability is not granted.
(c) Abuse. The requesting spouse was abused by
the nonrequesting spouse, but such abuse did not amount
to duress.
(d) No knowledge or reason to know. In the case
of a liability that was properly reported but not paid,
the requesting spouse did not know and had no reason to
know that the liability would not be paid. In the case
of a liability that arose from a deficiency, the
requesting spouse did not know and had no reason to
know of the items giving rise to the deficiency.
(e) Nonrequesting spouse’s legal obligation. The
nonrequesting spouse has a legal obligation pursuant to
a divorce decree or agreement to pay the outstanding
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