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Commissioner, 119 T.C. 306, 311 (2002) (“Except as otherwise
provided in section 6015, petitioner bears the burden of
proof.”); Jonson v. Commissioner, supra at 113 (same).
As directed by section 6015(f), respondent has prescribed
procedures to use in determining whether a relief-seeking spouse
qualifies for relief under section 6015(f). At the time that
petitioner filed her Petition for Determination of Relief from
Joint and Several Liability on a Joint Return, March 10, 2002,
those procedures were found in Rev. Proc. 2000-15, 2000-1 C.B.
447. Section 4.01 of Rev. Proc. 2000-15, 2000-1 C.B. at 448,
lists seven threshold conditions that must be satisfied before
respondent will consider a request for relief under section
6015(f). The threshold conditions are as follows:
(1) The requesting spouse filed a joint return for
the taxable year for which relief is sought;
(2) Relief is not available to the requesting
spouse under [section] 6015(b) or 6015(c);
(3) The requesting spouse applies for relief no
later than two years after the date of the Service’s
first collection activity after July 22, 1998, with
respect to the requesting spouse;
(4) * * * the liability remains unpaid. * * *
(5) No assets were transferred between the spouses
filing the joint return as part of a fraudulent scheme
by such spouses;
(6) There were no disqualified assets transferred
to the requesting spouse by the nonrequesting spouse.
If there were disqualified assets transferred to the
requesting spouse by the nonrequesting spouse, relief
will be available only to the extent that the liability
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