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Pursuant to section 6015(f), the Commissioner has prescribed
guidelines in Rev. Proc. 2000-15, 2000-1 C.B. 447, for
determining whether a requesting spouse qualifies for equitable
relief under that section.14 In this case, although the notice
of determination does not state that respondent utilized the
guidelines in Rev. Proc. 2000-15, supra, to make his
determination that petitioner is not entitled to relief under
section 6015(f), the notice of determination refers to
respondent’s analysis of factors, and we assume that respondent’s
reference to factors in the notice of determination is to the
factors enumerated in Rev. Proc. 2000-15, supra. This Court has
upheld the use of the guidelines specified in Rev. Proc. 2000-15,
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 the
guidelines contained in Rev. Proc. 2000-15, supra, 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
14On Aug. 11, 2003, the Commissioner issued Rev. Proc. 2003-
61, 2003-32 I.R.B. 296, which supersedes Rev. Proc. 2000-15,
2001-1 C.B. 447. The new revenue procedure is effective for
requests for relief filed on or after Nov. 1, 2003, and,
therefore, is inapplicable here.
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