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satisfies the threshold conditions, section 4.01 of Revenue
Procedure 2000-15 provides that a requesting spouse may be
relieved under section 6015(f) of all or part of the liability in
question if, taking into account all of the facts and circum-
stances, the IRS determines that it would be inequitable to hold
the requesting spouse liable for such liability.
Where, as here, the requesting spouse satisfies the thresh-
old conditions set forth in section 4.01 of Revenue Procedure
2000-15, section 4.02 of that revenue procedure sets forth the
circumstances, in any case where a liability reported in a joint
return is unpaid, under which the IRS ordinarily will grant
relief to that spouse under section 6015(f). In the instant
case, the liability from which relief is sought arises from a
deficiency. Therefore, section 4.02 of Revenue Procedure 2000-15
is not applicable here.23 However, where, as here, the request-
ing spouse fails to qualify for relief under section 4.02 of that
revenue procedure, the IRS may nonetheless grant the requesting
spouse relief under section 4.03 of Revenue Procedure 2000-15.
That section provides a partial list of positive and negative
factors which respondent is to take into account in considering
23Assuming arguendo that sec. 4.02, Rev. Proc. 2000-15,
2000-1 C.B. 448, were applicable in the instant case, petitioner
would not qualify for relief under that section of that revenue
procedure. That is because petitioner has failed to show that
the circumstances set forth in sec. 4.02 of Revenue Procedure
2000-15 are present in the instant case.
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