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Commissioner will consider a request for relief under section
6015(f). Respondent concedes that petitioner satisfied 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.
4.02,15 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 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 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.
15Rev. 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, and not unpaid liabilities reported on joint
returns, Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, does
not apply. See Mellen v. Commissioner, T.C. Memo. 2002-280.
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