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6015(f). See Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448.
Respondent agrees that petitioner satisfies these threshold
conditions for the year under consideration, and we focus our
attention on other parts of the controlling revenue procedure.
Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, describes
the circumstances under which the Commissioner will “ordinarily”
grant equitable relief in cases where a liability reported on a
joint return is unpaid. Rev. Proc. 2000-15, sec. 4.02(1)
provides that equitable relief will ordinarily be granted if all
of the following elements are satisfied:
(a) At the time relief is requested, the
requesting spouse is no longer married to, or is legally
separated from, the nonrequesting spouse * * *;
(b) At the time the return was signed, the
requesting spouse had no knowledge or reason to know
that the tax would not be paid. The requesting spouse
must establish that it was reasonable for the requesting
spouse to believe that the nonrequesting spouse would
pay the reported liability. * * *; and
(c) The requesting spouse will suffer economic
hardship if relief is not granted. For purposes of this
section, the determination of whether a requesting
spouse will suffer economic hardship will be made by the
Commissioner or the Commissioner’s delegate, and will be
based on rules similar to those provided in � 301.6343-
1(b)(4) of the Regulations on Procedure and
Administration.
Respondent concedes that petitioner satisfies the first
requirement but argues that petitioner does not qualify for
relief under Rev. Proc. 2000-15, sec. 4.02 because she:
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