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declined to consider them where the liability for which equitable
relief was sought was not such a reported but unpaid liability.
See, e.g., Mellen v. Commissioner, T.C. Memo. 2002-280. In the
instant case, the 1992-1994 interest liability is not a liability
that was reported on a joint return that remains unpaid. Rather,
the 1992-1994 interest liability resulted from an understatement
of tax on a joint return. Consequently, Rev. Proc. 2000-15,
sec. 4.02, 2000-1 C.B. at 448, is not applicable here.
If the requesting spouse satisfies the threshold conditions
of Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448, but does
not qualify for relief under Rev. Proc. 2000-15, sec. 4.02,
2000-1 C.B. at 448, respondent 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, 2000-1 C.B. at 448, provides a partial list of positive and
negative factors that respondent is to take into account when
considering whether to grant an individual full or partial
equitable relief under section 6015(f). As Rev. Proc. 2000-15,
sec. 4.03, 2000-1 C.B. at 448, makes clear, no single factor is
to be determinative in any particular case, all factors are to be
considered and weighed appropriately, and the list of factors is
not intended to be exhaustive.
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, lists the
following two factors that, if true, respondent weighs in favor
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