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taxpayers seeking equitable relief from joint and several
liability. Notice 98-61, supra, was superseded by Rev. Proc.
2000-15, 2000-1 C.B. 447, effective January 18, 2000, which, in
turn, was superseded by Rev. Proc. 2003-61, 2003-32 I.R.B. 296,
effective for requests for relief filed on or after November 1,
2003, and for requests for relief pending on November 1, 2003,
for which no preliminary determination had been issued as of that
date. Rev. Proc. 2003-61, secs. 6 and 7, 2003-32 I.R.B. at 299;
Rev. Proc. 2000-15, secs. 6 and 7, 2000-1 C.B. at 449.
Petitioner’s request for relief and respondent’s determination
are subject to Rev. Proc. 2000-15, 2000-1 C.B. 447, because that
revenue procedure was in effect when respondent evaluated
petitioner’s request and when respondent issued the notice of
determination on March 8, 2001. See Ewing v. Commissioner, supra
at 44 n.12. This Court has upheld the use of these procedures in
reviewing a negative determination. See, e.g., Washington v.
Commissioner, supra at 147-152; Jonson v. Commissioner, supra at
125-126; cf. Ewing v. Commissioner, supra at 45. (Subsequent
modification of these procedures by Rev. Proc. 2003-61, 2003-32
I.R.B. 296, does not affect our analysis of this case.)
Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448, lists
seven threshold conditions that must be satisfied before the
Commissioner will consider a request for relief under section
6015(f). Respondent conceded that petitioner has met those seven
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