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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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