Eleanor Simon - Page 19

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          liability in question.  Section 4.01 of Revenue Procedure 2000-15           
          lists seven conditions (threshold conditions) which must be                 
          satisfied before the IRS will consider a request for relief under           
          section 6015(f).  In the instant case, respondent concedes that             
          those conditions are satisfied.  Where, as here, the requesting             
          spouse satisfies the threshold conditions, section 4.01 of                  
          Revenue Procedure 2000-15 provides that a requesting spouse may             
          be relieved under section 6015(f) of all or part of the liability           
          in question if, taking into account all the facts and circum-               
          stances, the IRS determines that it would be inequitable to hold            
          the requesting spouse liable for such liability.                            
               Where, as here, the requesting spouse satisfies the thresh-            
          old conditions, section 4.02(1) of Revenue Procedure 2000-15 sets           
          forth the circumstances under which the IRS ordinarily will grant           
          relief to that spouse under section 6015(f) in a case, like the             
          instant case, where a liability is reported in a joint return but           
          not paid.  As pertinent here, those circumstances, which section            
          4.02 of Revenue Procedure 2000-15 and we refer to as elements,              
                    (a) At the time relief is requested, the request-                 
               ing spouse is no longer married to * * * the                           
               nonrequesting spouse * * *;                                            
                    (b) At the time the return was signed, the re-                    
               questing 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                                

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