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July 22, 1998. The Court, therefore, considers petitioner's
entitlement to relief under Rev. Proc. 2000-15, sec. 4.02, supra.
If a requesting spouse satisfies all of the applicable
threshold conditions, Rev. Proc. 2000-15, sec. 4.01, provides
that such spouse may be entitled to relief under section 6015(f)
if, taking into account all of the facts and circumstances, the
IRS determines that it would be inequitable to hold the
requesting spouse liable for such liability. Where a liability
reported on a joint return is unpaid, Rev. Proc. 2000-14, sec.
4.02, provides the circumstances under which equitable relief
under section 6015(f) will ordinarily be granted. Where, as
here, a taxpayer does not qualify for relief under section 4.02,
the IRS may still grant relief under section 4.03. Rev. Proc.
2000-15, sec. 4.03, supra, provides a partial list of positive
and negative factors that will be taken into account in
determining whether full or partial relief will be granted 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. Collier v. Commissioner, T.C. Memo. 2002-144; Rev.
Proc. 2000-15, sec. 4.03.
Rev. Proc. 2000-15, sec. 4.03(a), supra, sets forth positive
factors that weigh in favor of relief. As pertinent here, that
section provides:
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