Jeanine T. Foor - Page 6

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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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