Curtis Earl Moore - Page 14

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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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