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not qualify for relief under Rev. Proc. 2000-15, sec. 4.02,
2000-1 C.B. at 448, the Commissioner looks to Rev. Proc. 2000-15,
sec. 4.03, 2000-1 C.B. at 448, to determine whether the taxpayer
should be granted equitable relief. Rev. Proc. 2000-15,
sec. 4.03, 2000-1 C.B. at 448, provides a partial list of
positive and negative factors that the Commissioner is to take
into account when considering whether to grant an individual full
or partial equitable relief under section 6015(f). As Rev. Proc.
2000-15, sec. 4.03, 2000-1 C.B. at 448, makes clear, no single
factor is to be determinative in any particular case, all factors
are to be considered and weighed appropriately, and the list of
factors is not intended to be exhaustive.
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, lists the
following two factors that, if true, the Commissioner weighs in
favor of granting relief and that, if not true, are neutral:
(1) The taxpayer is separated or divorced from the nonrequesting
spouse and (2) the taxpayer was abused by his or her spouse.
Respondent conceded that the marital status factor weighs in
petitioner’s favor. The abuse factor is neutral in this case
because petitioner failed to provide any detailed or
corroborating evidence with respect to her generalized claim that
intervenor was physically and emotionally abusive.
In addition, Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at
448, lists the following two factors that, if true, the
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