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section 6015(f). Rev. Proc. 2000-15, supra, applies to requests
for equitable relief with respect to any liability for tax
arising on or before July 22, 1998, that was unpaid on that date.
Rev. Proc. 2000-15, sec. 3, 2000-1 C.B. at 448.
Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448, lists the
threshold conditions that must be satisfied before the
Commissioner will consider a request for equitable relief under
section 6015(f). We find that petitioner has satisfied the
threshold conditions.
Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, lists the
circumstances under which equitable relief will ordinarily be
granted. Rev. Proc. 2000-15, sec. 4.02(2)(b) provides that
“Relief will only be available to the extent that the unpaid
liability is allocable to the nonrequesting spouse.” The unpaid
liability for taxable year 1995 arose from the omission of
petitioner’s income. Thus, petitioner does not qualify for
equitable relief under section 4.02.
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448-449, in
relevant part, provides a nonexhaustive list of positive and
negative factors for determining whether to grant equitable
relief to a requesting spouse who does not qualify for relief
under section 4.02.
We find that the factors overwhelmingly weigh against
relief. First, the unpaid liability arose from an omission of
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