Ruthe G. Ohrman - Page 29

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               exceeds the value of such disqualified assets.  For                    
               this purpose, the term “disqualified asset” has such                   
               meaning given such term by section 6015(c)(4)(B); and                  
                    (7) The requesting spouse did not file the return                 
               with fraudulent intent.                                                
          Id.  A requesting spouse must satisfy all seven threshold                   
          conditions before respondent will consider his or her request for           
          equitable relief under section 6015(f).  Id.  We have upheld the            
          use of these procedures in reviewing a negative determination.              
          See Washington v. Commissioner, supra at 147; Jonson v.                     
          Commissioner, supra at 125.                                                 
               Respondent denied petitioner’s request for equitable relief            
          under section 6015(f) because she did not meet all seven of the             
          threshold conditions listed above.  Specifically, respondent                
          concluded that petitioner received a transfer of disqualified               
          assets from Mr. Ohrman in violation of the sixth condition of               
          Rev. Proc. 2000-15, sec. 4.01.  Respondent reached this                     
          conclusion by considering the time line of events beginning with            
          petitioner’s receipt of the May 29, 2001, letter of proposed                
          changes to petitioner’s and Mr. Ohrman’s reported tax liability             
          for 1999, the transfer of assets from Mr. Ohrman to petitioner              
          pursuant to the separation agreement, and statements made by                
          petitioner and Mr. Ohrman during their separate interviews with             
          respondent.  Petitioner maintains that she did not receive a                
          transfer of disqualified assets; thus, petitioner argues that she           

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