Kathleen E. Gilliam - Page 8

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          the procedures in reviewing a determination.  Washington v.                 
          Commissioner, 120 T.C. 137, 147-152 (2003).                                 
               Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448, provides            
          seven threshold conditions that must be satisfied before the                
          Commissioner will consider a request for equitable relief under             
          section 6015(f).  Respondent does not raise any argument with               
          respect to these seven threshold conditions, and therefore, we              
          presume that they have been satisfied and consider other                    
          provisions of the revenue procedure.                                        
               Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, sets                
          forth positive and negative factors that are to be considered in            
          determining whether to grant relief.  The revenue procedure makes           
          clear that no single factor is to be determinative in any                   
          particular case, that all factors are to be considered and                  
          weighed appropriately, and that the list of factors is not                  
          intended to be exhaustive.                                                  
               a. Factors Against Relief                                              
               We first review each of the following six factors weighing             
          against relief, as listed under Rev. Proc. 2000-15, sec. 4.03(2),           
          2001-1 C.B. at 449.                                                         
               i.  Attributable to Nonrequesting Spouse                               
               The liability for which relief is sought is not solely                 
          attributable to petitioner.  This factor is squarely against                

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