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requesting spouse [petitioner].
We reject petitioner’s views regarding the nature of the relief
from joint and several liability provided by section 6015.
Relief under that section from joint and several liability is
not, as petitioner alleges, the temporary suspension of such
liability. See sec. 6015.
By way of further illustration, petitioner argues on brief
that Revenue Procedure 2000-15, 2000-1 C.B. 447 (Revenue Proce-
dure 2000-15), which prescribes procedures that are to be used in
determining whether an individual qualifies for relief under
section 6015(f), “is fundamentally flawed in that it unduly
limits the broad application of the statute seeking to provide
tax collection relief to a spouse” and considers facts and/or
circumstances that are “legally irrelevant” and inappropriate in
this case. We reject those arguments about Revenue Procedure
2000-15.
As directed by section 6015(f), respondent has prescribed
procedures in Revenue Procedure 2000-15 that are to be used in
determining whether an individual qualifies for relief under that
section. Section 4.01 of Revenue Procedure 2000-15 lists seven
conditions (threshold conditions) which must be satisfied before
the IRS will consider a request for relief under section 6015(f).
Respondent concedes that those threshold conditions are satisfied
in the instant case. Where, as here, the requesting spouse
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