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of equitable relief is reviewed under an abuse of discretion
standard. Washington v. Commissioner, 120 T.C. 137, 146 (2003).
In deciding whether the determination was an abuse of discretion,
we consider evidence relating to all the facts and circumstances.
Id. at 148.
Rev. Proc. 2000-15, 2000-1 C.B. 447, contains guidelines
that are considered in determining whether an individual
qualifies for relief under section 6015(f).2 Rev. Proc. 2000-15,
sec. 4.01, 2000-1 C.B. at 448, lists seven threshold conditions
that must be satisfied before the Commissioner will consider a
request for relief under section 6015(f). Respondent agrees that
the threshold conditions are satisfied in this case.
Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, provides
that, in cases where a liability reported on a joint return is
unpaid, relief under section 6015(f) will ordinarily be granted
if three elements are satisfied. Because petitioner is still
married to and living with Mr. Sjodin, she does not meet the
requirements of Rev. Proc. 2000-15, sec. 4.02.
If relief is not available under Rev. Proc. 2000-15, sec.
4.02, then Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448,
provides factors that the Commissioner will consider in deciding
2On 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.
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