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applicable threshold conditions, section 4.01 of Revenue Proce-
dure 2000-15 provides that that spouse is entitled to relief
under section 6015(f) for all or part of the liability in ques-
tion if, taking into account all of the facts and circumstances,
12(...continued)
.01 Eligibility to be considered for equitable
relief. All the following threshold conditions must be
satisfied before the Service will consider a request
for equitable relief under � 6015(f). * * *
(1) The requesting spouse filed a joint
return for the taxable year for which relief is sought;
(2) Relief is not available to the requesting
spouse under � 6015(b) or 6015(c);
(3) The requesting spouse applies for relief
no later than two years after the date of the Service’s
first collection activity after July 22, 1998, with
respect to the requesting spouse;
(4) * * * the liability remains unpaid. * * *
(5) No assets were transferred between the
spouses filing the joint return as part of a fraudulent
scheme by such spouses;
(6) There were no disqualified assets trans-
ferred to the requesting spouse by the nonrequesting
spouse. * * * For this purpose, the term “disqualified
asset” has the meaning given such term by �
6015(c)(4)(B); and
(7) The requesting spouse did not file the
return with fraudulent intent.
A requesting spouse satisfying all the applicable
threshold conditions set forth above may be relieved of
all or part of the liability under � 6015(f) * * *, if,
taking into account all the facts and circumstances,
the Service determines that it would be inequitable to
hold the requesting spouse liable for such liability.
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