Susan L. Abelein - Page 31

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          448-449, contains a list of positive and negative factors that              
          the Commissioner must take into account in determining, on the              
          facts and circumstances, whether to grant full or partial                   
          equitable relief under section 6015(f).  As Rev. Proc. 2000-15,             
          sec. 4.03 makes clear, no single factor is determinative in any             
          particular case, all factors are to be considered and weighed               
          appropriately, and the listing of factors is not intended to be             
          exhaustive.  See also Washington v. Commissioner, supra at 148;             
          Jonson v. Commissioner, supra at 125.                                       
              Rev. Proc. 2000-15, sec. 4.03(1) lists the following six               
          positive factors that the Commissioner will weigh in favor of               
          granting equitable relief:                                                  
                    (a) Marital status.  The requesting spouse is                     
               separated * * * or divorced from the nonrequesting                     
               spouse.                                                                
                    (b) Economic hardship.  The requesting spouse                     
               would suffer economic hardship (within the meaning of                  
               section 4.02(1)(c) of this revenue procedure) if relief                
               from the liability is not granted.                                     
                    (c) Abuse.  The requesting spouse was abused by                   
               the nonrequesting spouse, but such abuse did not amount                
               to duress.                                                             
                    (d) No knowledge or reason to know.  In the case                  
               of a liability that was properly reported but not paid,                
               the requesting spouse did not know and had no reason to                
               know that the liability would not be paid.  In the case                
               of a liability that arose from a deficiency, the                       
               requesting spouse did not know and had no reason to                    
               know of the items giving rise to the deficiency.                       
                    (e) Nonrequesting spouse’s legal obligation.  The                 
               nonrequesting spouse has a legal obligation pursuant to                
               a divorce decree or agreement to pay the outstanding                   





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