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circumstances, it is inequitable to hold the individual liable
for any unpaid tax or any deficiency (or any portion thereof)”.
See Ewing v. Commissioner, 118 T.C. at 500; see also Fernandez v.
Commissioner, supra at 330; Foor v. Commissioner, T.C. Memo.
2004-54.
As directed by section 6015(f), the Commissioner has
prescribed procedures to use in determining whether a requesting
spouse qualifies for relief under subsection (f). When
respondent issued his notice of determination to petitioner,
those procedures were found in Rev. Proc. 2000-15, 2000-1 C.B.
447. This Court has upheld the use of these procedures in
reviewing a negative determination. See, e.g., Washington v.
Commissioner, supra at 147-152; Jonson v. Commissioner, supra at
125-126.
Seven threshold conditions must be satisfied before the
Commissioner will consider a request for relief under section
6015(f). Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448.
Respondent agrees petitioner satisfies those threshold
conditions.
Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, lists
three conditions, which, if met, ordinarily will persuade the
Commissioner to grant relief from unpaid liabilities reported on
a joint return. As applicable here, these conditions are:
(a) At the time relief is requested, the
requesting spouse is no longer married to * * * the
nonrequesting spouse * * *;
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