- 14 -
6015(f). Washington v. Commissioner, supra at 146; Jonson v.
Commissioner, supra at 125.
As directed by section 6015(f), respondent has prescribed
procedures to use in determining whether a relief-seeking spouse
qualifies for relief under that subsection. At the time that
respondent issued his notice of determination to petitioner,
those procedures were found 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, e.g., Washington v.
Commissioner, supra at 147-152; Jonson v. Commissioner, supra at
125-126.
Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448, lists
seven threshold conditions that must be satisfied before
respondent will consider a request for relief under section
6015(f). Respondent conceded that petitioner has met those seven
threshold conditions. 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 in cases
where a liability reported on a joint return is unpaid. We have
considered the circumstances listed in Rev. Proc. 2000-15, sec.
4.02, 2000-1 C.B. at 448, in cases where the liability reported
on a joint return was unpaid. See, e.g., August v. Commissioner,
T.C. Memo. 2002-201; Collier v. Commissioner, T.C. Memo. 2002-
144; Castle v. Commissioner, T.C. Memo. 2002-142. We have
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