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the Secretary may relieve such individual of such liability.
The Court applies an abuse of discretion standard to review
respondent’s determinations under section 6015(f). Jonson v.
Commissioner, 118 T.C. 106, 125 (2002); Cheshire v. Commissioner,
115 T.C. 183, 198 (2000), affd. 282 F.3d 326 (5th Cir. 2002);
Butler v. Commissioner, 114 T.C. 276, 292 (2000).
As directed by section 6015(f), the Commissioner prescribed
procedures to use in determining whether the requesting spouse
qualifies for relief under section 6015(f). Those procedures are
found in Rev. Proc. 2000-15, 2000-1 C.B. 447. Rev. Proc. 2000-
15, sec. 3, 2000-1 C.B. at 448, is applicable to any liability
for tax arising on or before July 28, 1998, that was unpaid on
that date. The revenue procedure includes a partial list of the
positive and negative factors to be considered, including whether
the requesting spouse is divorced, whether the requesting spouse
would suffer undue economic hardship, whether the requesting
spouse had no reason to know that the liability would not be
paid, and whether the requesting spouse significantly benefitted
beyond normal support from the unpaid liability. Id. sec.
4.03(1) and (2), 2000-1 C.B. at 448-449. “No single factor will
be determinative of whether equitable relief will or will not be
granted in any particular case. Rather, all factors will be
considered and weighed appropriately.” Id. sec. 4.03.
In concluding that petitioner be granted full relief from
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