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supra, and has analyzed the factors listed in Rev. Proc. 2000-15,
supra, in reviewing the Commissioner’s negative determination
under section 6015(f). See, e.g., Washington v. Commissioner,
120 T.C. 137, 147-152 (2003); Jonson v. Commissioner, supra at
125-126. Moreover, petitioner has not objected to the use of
these guidelines, and she has addressed the factors in her
posttrial briefs.
Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448, lists
seven threshold conditions that must be satisfied before the
Commissioner will consider a request for relief under section
6015(f). Respondent concedes that petitioner satisfies the seven
threshold conditions.
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, provides
that, in cases where the threshold conditions set forth in Rev.
Proc. 2000-15, sec. 4.01 have been satisfied but the requesting
spouse does not qualify for relief under Rev. Proc. 2000-15, sec.
4.02,13 2000-1 C.B. at 448, equitable relief may be granted under
section 6015(f) if, taking into account all facts and
circumstances, it is inequitable to hold the requesting spouse
liable. Rev. Proc. 2000-15, sec. 4.03(1) and (2), 2000-1 C.B. at
13Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. 447, 448, lists
the circumstances under which equitable relief under sec. 6015(f)
will ordinarily be granted in cases where a liability reported on
a joint return is unpaid. Because this case involves
deficiencies, not unpaid liabilities reported on joint returns,
Rev. Proc. 2000-15, sec. 4.02 does not apply. See Mellen v.
Commissioner, T.C. Memo. 2002-280.
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