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the years at issue all of the elements set forth in section
4.02(1) of Revenue Procedure 2000-15 under which the Service will
ordinarily grant equitable relief under section 6015(f) are
present in the instant case.
Although Ms. Collier has not shown that she qualifies for
relief under section 4.02(1) of Revenue Procedure 2000-15, the
Service 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 full or partial equitable 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. 447, 448.
Turning to the partial list of positive factors set forth in
section 4.03(1) of Revenue Procedure 2000-15 that weigh in favor
of relief,22 Ms. Collier contends that each of those factors is
22As pertinent here, sec. 4.03(1) of Revenue Procedure 2000-
15 provides:
(1) Factors weighing in favor of relief. The
factors weighing in favor of relief include, but are
not limited to, the following:
(a) Marital status. The requesting spouse is
* * * divorced from the nonrequesting spouse.
(continued...)
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