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or deficiency, and full or partial equitable relief under section
6015(f) should be granted. Rev. Proc. 2000-15, sec. 4.03(1),
2000-1 C.B. at 448-449, provides that the following factors weigh
in favor of the Commissioner’s granting equitable relief: (1)
Marital status, (2) economic hardship, (3) abuse, (4) no
knowledge or reason to know, (5) nonrequesting spouse’s legal
obligation, and (6) attributable to nonrequesting spouse. Rev.
Proc. 2000-15, sec. 4.03(2), 2000-1 C.B. at 449, provides that
the following factors weigh against the Commissioner’s granting
equitable relief: (1) Attributable to requesting spouse, (2)
knowledge, or reason to know, (3) significant benefit, (4) lack
of economic hardship, (5) noncompliance with Federal income tax
laws, and (6) requesting spouse’s legal obligation. Further,
Rev. Proc. 2000-15, supra, provides that no single factor will be
determinative, but that all relevant factors, regardless of
whether the factor is listed in Rev. Proc. 2000-15, sec. 4.03,
will be considered and weighed.
To prevail under section 6015(f), petitioner must show that
respondent’s denial of equitable relief from joint liability
under section 6015(f) was an abuse of discretion. See Washington
v. Commissioner, 120 T.C. at 146; Jonson v. Commissioner, 118
T.C. 106, 125 (2002) (citing Butler v. Commissioner, 114 T.C.
276, 292 (2000)), affd. 353 F.3d 1181 (10th Cir. 2003). Action
constitutes an abuse of discretion under this standard where it
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