S.W. DePasture - Page 18





                                       - 17 -                                         
               As relevant here, a nonexclusive list of factors the                   
          Commissioner will consider in allowing relief under section                 
          6015(f) is set forth in section 4.03 of Rev. Proc. 2000-15, 2000-           
          1 C.B. 448.  No single factor is determinative; rather, all                 
          factors are considered and weighed appropriately.  See Mellen v.            
          Commissioner, T.C. Memo. 2002-280; Penfield v. Commissioner, T.C.           
          Memo. 2002-254.                                                             
               Knowledge of an item giving rise to the deficiency “is an              
          extremely strong factor weighing against relief.”  Rev. Proc.               
          2000-15, sec. 4.03(2)(b), 2000-1 C.B. 449.  As we have previously           
          discussed, petitioner was aware of the items that give rise to              
          the deficiencies in this case.                                              
               Furthermore, relief might not be appropriate under section             
          6015(f) if the individual who requests such relief benefited from           
          the unpaid liability or items giving rise to the deficiency.  See           
          Rev. Proc. 2000-15, sec. 4.03(2)(c), 2000-1 C.B. 449.  In this              
          case, petitioner significantly benefited from the items that                
          resulted in the deficiencies here under consideration.  Some of             
          his personal and family living expenses were paid by CWS during             
          each year in issue, and, in 1995, he received from CWS an                   
          ownership interest in a valuable piece of real estate.                      











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