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v. Commissioner, 118 T.C. 494, 506-507 (2002), we held that we
have jurisdiction to review claims for section 6015(f) relief
similar to petitioner’s claim.
Under section 6015(f), whether it would be inequitable for a
requesting spouse to be held jointly liable for unpaid taxes
“requires a careful consideration of all possible factors that
are relevant” to the inquiry. Alt v. Commissioner, 101 Fed.
Appx. 34, 39-40 (6th Cir. 2004) (quoting Silverman v.
Commissioner, 116 F.3d 172, 175 (6th Cir. 1997), revg. T.C. Memo.
1996-69), affg. 119 T.C. 306 (2002).
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. 447, 448-449,
sets forth guidelines or factors to consider in deciding claims
for equitable relief under section 6015(f) as follows:
(1) Whether the requesting spouse will suffer economic
hardship;
(2) Whether the requesting spouse, at the time the
return was signed, had knowledge or reason to know that the
liability reported on the return would not be paid;
(3) Whether the nonrequesting spouse has a legal
obligation to pay the unpaid joint Federal income taxes;
(4) Whether the underpayments of joint Federal income
taxes are attributable to the nonrequesting spouse;
(5) Whether the spouses are separated or divorced;
(6) Whether the requesting spouse suffered abuse by the
nonrequesting spouse;
(7) Whether the requesting spouse received significant
benefit, beyond normal support, as a result of the
underpayments of joint Federal income taxes; and
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