- 24 -
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, lists
factors that the Commissioner will consider in deciding whether
to grant equitable relief under section 6015(f). Rev. Proc.
2000-15, sec. 4.03(1), 2000-1 C.B. at 448-449, lists the
following six factors that the Commissioner will consider as
weighing in favor of granting relief for an unpaid liability:
(1) The requesting spouse is separated or divorced from the
nonrequesting spouse; (2) the requesting spouse would suffer
economic hardship if relief is denied; (3) the requesting spouse
was abused by the nonrequesting spouse; (4) the requesting spouse
did not know or have reason to know that the reported liability
would be unpaid; (5) the nonrequesting spouse has a legal
obligation pursuant to a divorce decree or agreement to pay the
unpaid liability; and (6) the unpaid liability is solely
attributable to the nonrequesting spouse.
Rev. Proc. 2000-15, sec. 4.03(2), 2000-1 C.B. at 449, lists
the following six factors that the Secretary will consider as
13(...continued)
in the instant case. Rev. Proc. 2003-61, supra, is effective for
requests for relief filed under sec. 6015(f) which are filed on
or after Nov. 1, 2003, and for requests for such relief which
were pending on, and for which no preliminary determination
letter has been issued as of, that date. Rev. Proc. 2003-61,
sec. 7, 2003-2 C.B. at 299. Here, petitioner’s Form 8857 was
filed on June 12, 2001, and was no longer pending on Nov. 1,
2003, as respondent denied her request for relief therein in
Notices dated Feb. 13 and Apr. 24, 2002.
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