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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(1) and (2), 2000-1 C.B. at
448, sets forth six positive and six 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. While we previously
discussed the factors weighing in favor of relief, such
discussion related to items to which we have held that petitioner
is entitled to relief under section 6015(b). Thus, we limit the
discussion of the factors as they relate to those adjustments
resulting in a deficiency from which we have held petitioner is
not entitled to relief; namely, the unreported unemployment
compensation and the disallowed itemized deductions. See sec.
6015(f)(2).
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