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respect to the requesting spouse”.4 See Rev. Proc. 2000-15, sec.
4.01(3), 2000-1 C.B. at 448. Respondent contends that petitioner
failed to satisfy this threshold condition.
We need not address respondent’s contention because, even if
petitioner could satisfy the threshold conditions, Rev. Proc.
2000-15, sec. 4.03, 2000-1 C.B. at 448, has a nonexhaustive list
of factors weighing in favor of relief and factors weighing
against relief, and petitioner has failed to present any evidence
with regard to these factors for determining whether to grant
equitable relief.5 Accordingly, we conclude that respondent did
not abuse his discretion by acting arbitrarily, capriciously, or
without sound basis in fact in denying petitioner’s request for
equitable relief under section 6015(f).
To reflect the foregoing,
Decision will be entered
for respondent.
4 Petitioner does not question the validity of this
threshold condition; therefore, we need not address its validity.
See Hall v. Commissioner, T.C. Memo. 2004-170 n.3.
5 As we indicated earlier, although respondent denied
equitable relief under sec. 6015(f) based upon the 2-year time
limit, respondent subsequently reviewed petitioner’s request
under the nonexhaustive list of factors of Rev. Proc. 2000-15,
sec. 4.03, 2000-1 C.B. 447, 448-449.
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