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expenses, the existence and amount of other debts, or the nature
and amount of the expenses she pays to care for her uncle.
Consequently, we conclude that petitioner has failed to prove
that she would be unable to pay her basic living expenses and
would suffer economic hardship if relief under section 6015(f)
were denied.
B. Revenue Procedure 2000-15, Section 4.03
Where the requesting spouse fails to qualify for relief
under Rev. Proc. 2000-15, sec. 4.02, the Commissioner may
nonetheless grant relief under Rev. Proc. 2000-15, sec. 4.03,
2000-1 C.B. at 448. Rev. Proc. 2000-15, sec. 4.03 provides that,
where the seven threshold conditions have been satisfied and the
requesting spouse does not qualify for relief under Rev. Proc.
2000-15, sec. 4.02, equitable relief may be granted under section
6015(f) if, taking into account all facts and circumstances, it
is inequitable to hold the requesting spouse liable. Rev. Proc.
2000-15, sec. 4.03(1) and (2), 2000-1 C.B. at 448-449, contains a
list of positive and negative factors that the Commissioner will
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
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