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request for relief under section 6015(f). Respondent agrees that
the threshold conditions are satisfied in this case.
Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, provides
that, in cases where a liability reported on a joint return is
unpaid, relief under section 6015(f) will ordinarily be granted
if the following three elements are satisfied: (1) At the time
relief is requested, the requesting spouse is no longer married
to or is legally separated from the nonrequesting spouse, or has
not been a member of the same household as the nonrequesting
spouse at any time during the 12-month period ending on the date
relief was requested; (2) at the time the return was signed, the
requesting spouse had no knowledge or reason to know that the tax
would not be paid; and (3) the requesting spouse will suffer
economic hardship if relief is not granted. Relief under Rev.
Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, is available only
to the extent that the unpaid liability is allocable to the
nonrequesting spouse. Id. sec. 4.02(2)(b).
If relief is not available under Rev. Proc. 2000-15, sec.
4.02, then Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448,
provides factors that the Commissioner will consider in deciding
whether to grant relief under section 6015(f). Rev. Proc. 2000-
15, sec. 4.03(1), 2000-1 C.B. at 448-449, lists the following six
factors weighing in favor of granting relief for an unpaid
liability: (1) The requesting spouse is separated or divorced
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