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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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