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that revenue procedure, on which she also relies in support of her
claim for relief with respect to each of the taxable years 1989,
1991, 1992, and 1993.
Section 4.03 of Revenue Procedure 2000-15 provides a partial
list of positive and negative factors which respondent is to take
into account in considering whether respondent will grant an
individual full or partial equitable relief under section 6015(f).
As Revenue Procedure 2000-15 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. 447, 448.
We turn now to the application of section 4.03 of Revenue
Procedure 2000-15 to this case. Section 4.03(1) of Revenue
Procedure 2000-15 sets forth the following positive factors which
weigh in favor of granting relief under section 6015(f):
(a) Marital status. The requesting spouse is
separated * * * or divorced from the nonrequesting
spouse.
(b) Economic hardship. The requesting spouse would
suffer economic hardship (within the meaning of section
4.02(1)(c) of this revenue procedure) if relief from the
liability is not granted.
(c) Abuse. The requesting spouse was abused by the
nonrequesting spouse, but such abuse did not amount to
duress.
(d) No knowledge or reason to know. In the case of
a liability that was properly reported but not paid, the
requesting spouse did not know and had no reason to know
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