Sandrus L. Collier - Page 29

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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.                          

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