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are set forth in Rev. Proc. 2000-15, 2000-1 C.B. 447. This Court
has upheld the use of these procedures in reviewing a negative
determination. See Washington v. Commissioner, supra at 147;
Jonson v. Commissioner, supra at 125. Rev. Proc. 2000-15, sec.
4.01, 2000-1 C.B. at 448, lists seven conditions (threshold
conditions) that must be satisfied before the Commissioner will
consider a request for relief under section 6015(f).
If the threshold conditions are satisfied, Rev. Proc.
2000-15, sec. 4.02, 2000-1 C.B. at 448, lists circumstances where
relief will generally be granted, subject to two limitations. If
it is unclear whether these circumstances are satisfied, the
Commissioner looks to Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B.
at 448, to determine whether the taxpayer should be granted
equitable relief.
Rev. Proc. 2000-15, sec. 4.03(1), 2000-1 C.B. at 448, lists
the following six factors that the Commissioner will consider as
weighing in favor of granting relief for an unpaid liability
(positive factors): (1) The requesting spouse is separated or
divorced from the nonrequesting spouse; (2) the requesting spouse
would suffer economic hardship if relief were denied; (3) the
requesting spouse was abused by the nonrequesting spouse; (4) the
requesting spouse did not know or have reason to know that the
reported liability would be unpaid at the time that the return
was signed; (5) the nonrequesting spouse has a legal obligation
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Last modified: May 25, 2011