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for relief from joint and several liability under section
6015(f).4 We review the Commissioner’s denial of relief under
section 6015(f) for abuse of discretion. See Washington v.
Commissioner, 120 T.C. 137, 146 (2003); Butler v. Commissioner,
supra at 292.
Before the Commissioner will consider a taxpayer’s request
for relief under section 6015(f), the taxpayer must satisfy seven
threshold conditions listed in Rev. Proc. 2000-15, sec. 4.01,
2000-1 C.B. at 448. Respondent concedes that petitioner
satisfies these conditions.
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, provides
that equitable relief may be granted under section 6015(f) if,
taking into account all facts and circumstances, it is
inequitable to hold the requesting spouse liable. In considering
a request for relief, certain factors weigh in favor of granting
relief, whereas other factors weigh against granting relief. See
id. No single factor is determinative in any particular case,
and all factors are to be considered and weighed appropriately.
See Washington v. Commissioner, supra at 148; Jonson v.
Commissioner, 118 T.C. 106, 125 (2002), affd. 353 F.3d 1181 (10th
4On Aug. 11, 2003, the Commissioner issued Rev. Proc. 2003-
61, 2003-32 I.R.B. 296, which supersedes Rev. Proc. 2000-15,
2000-1 C.B. 447, effective for requests for relief filed on or
after Nov. 1, 2003, and for requests for relief pending on Nov.
1, 2003, for which no preliminary determination letter has been
issued as of that date.
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