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6015(f), and it states that “[n]o single factor will be
determinative * * * in any particular case. Rather, all factors
will be considered and weighed appropriately.” Rev. Proc. 2000-
15, section 4.03(1) and (2), 2000-1 C.B. at 448-449, sets forth
the “partial list” of factors that the Commissioner will consider
in deciding whether to grant equitable relief under section
6015(f). Section 4.03(1) of the revenue procedure lists six
factors the presence or absence of which weighs in favor of
granting equitable relief (positive factors), and section 4.03(2)
of the revenue procedure lists six factors the presence or
absence of which weighs against granting equitable relief
(negative factors). Four of the six factors on each list have a
reciprocal opposite on the other list, so that the presence or
absence of the circumstance referred to will necessarily be
positive or negative.7 The absence of the circumstances referred
to by either or both of the other two factors on each list is
considered neutral under Rev. Proc. 2000-15, section 4.03.
Because four of the six factors on each list are common to both
lists, there are actually eight separate and distinct factors set
forth in Rev. Proc. 2000-15, section 4.03.
7 In one case, the reciprocal circumstances are that “[t]he
nonrequesting spouse has a legal obligation pursuant to a divorce
decree or agreement to pay the outstanding liability” (positive)
or, conversely, that the requesting spouse bears that obligation
(negative). If neither spouse bears that obligation, the
resulting absence of the factor is necessarily neutral.
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