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legally separated, or have lived apart for a 12-month period. Such
spouses may elect to be treated, for purposes of determining tax
liability, as if separate returns had been filed. Section
6015(c)(1) provides proportionate relief for any “deficiency which
is assessed with respect to the return”. Relief is not available
under section 6015(c) with respect to an unpaid liability for tax
reported on the return. As noted, in this case, petitioner is
seeking relief of the amount reflected as the balance due on the
1989 joint return. Because there is no “deficiency” for 1989,
relief is not available to petitioner under section 6015(c).
Consequently, the only avenue for relief available to petitioner is
section 6015(f).
As directed by section 6015(f), the Commissioner has
prescribed guidelines in Rev. Proc. 2000-15, 2000-1 C.B. 447, 448,
that the Commissioner will consider in determining whether an
individual qualifies for relief under section 6015(f). Section
4.01 of Rev. Proc. 2000-15, 2000-1 C.B. at 448, lists seven
conditions (threshold conditions) which must be satisfied before
the Commissioner will consider a request for relief under section
6015(f). Respondent agrees that in this case those threshold
conditions are satisfied.
Section 4.03 of Rev. Proc. 2000-15, 2000-1 C.B. at 448-449,
lists factors that the Commissioner will consider in deciding
whether to grant equitable relief under section 6015(f). Section
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