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whether respondent will grant an individual full or partial
equitable relief under section 6015(f). As Revenue Procedure
2000-15 makes clear, 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.
We now turn to the application of section 4.03 of Revenue
Procedure 2000-15 to the record established in the instant case.
As pertinent here, section 4.03(1) of Revenue Procedure 2000-15
sets forth the following positive factors which weigh in favor of
granting relief under section 6015(f):
(a) Marital status. The requesting spouse is
* * * divorced from the nonrequesting spouse.
(b) Economic hardship. The requesting spouse
would suffer economic hardship (within the meaning of
section 4.02(1)(c) of this revenue procedure) if relief
from the liability is not granted.
(c) Abuse. The requesting spouse was abused by
the nonrequesting spouse, but such abuse did not amount
to duress.
(d) No knowledge or reason to know. * * * In the
case of a liability that arose from a deficiency, the
requesting spouse did not know and had no reason to
know of the items giving rise to the deficiency.
(e) Nonrequesting spouse’s legal obligation. The
nonrequesting spouse has a legal obligation pursuant to
a divorce decree or agreement to pay the outstanding
liability. This will not be a factor weighing in favor
of relief if the requesting spouse knew or had reason
to know, at the time the divorce decree or agreement
was entered into, that the nonrequesting spouse would
not pay the liability.
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