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threshold conditions. If the threshold conditions are satisfied,
Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, lists
circumstances where relief will generally be granted in cases
where a liability reported on a joint income tax return has gone
unpaid. We have considered the circumstances listed in Rev.
Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, in cases where the
liability reported on a joint income tax return was unpaid. See,
e.g., Morello v. Commissioner, T.C. Memo. 2004-181; August v.
Commissioner, T.C. Memo. 2002-201; Collier v. Commissioner, T.C.
Memo. 2002-144; Castle v. Commissioner, T.C. Memo. 2002-142. We
have declined to consider them where the liability for which
equitable relief was sought was not such a reported but unpaid
liability. See, e.g., Demirjian v. Commissioner, T.C. Memo.
2004-22; Mellen v. Commissioner, T.C. Memo. 2002-280. In the
instant case, petitioner and intervenor paid the income tax
liabilities reported on their joint income tax returns for 1990
through 1995 at or about the times that they filed these returns.
The additions to tax and interest resulted from, among other
things, petitioner’s and intervenor’s failure to file these
returns at the times that they were due. Consequently, Rev.
Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, is not applicable
here.
If the requesting spouse satisfies the threshold conditions
of Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448, but does
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