- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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