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Although petitioner has not shown that she qualifies for
relief under section 4.02(1) of Revenue Procedure 2000-15, the
IRS may nonetheless grant relief to her under section 4.03 of
that revenue procedure. That section provides a partial list of
positive and negative factors which respondent is to take into
account in considering whether respondent will grant an individ-
ual relief under section 6015(f). No single factor is to be
determinative in any particular case; all factors are to be
considered and weighed appropriately; and the list of factors is
not intended to be exhaustive. Rev. Proc. 2000-15, sec. 4.03,
2000-1 C.B. at 448.
As pertinent here, section 4.03(1) of Revenue Procedure
2000-15 sets forth the following positive factors which weigh in
favor of granting relief under section 6015(f):
(a) Marital status. The requesting spouse is * * *
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. * * *
(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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