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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
petitioner.
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