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relief under that subsection. At the time that petitioner
requested relief under section 6015(f), those procedures were set
forth in Rev. Proc. 2000-15, 2000-1 C.B. 447. (Subsequent
modification of these procedures by Rev. Proc. 2003-61, 2003-2
C.B. 296, does not affect the resolution of this case.)
Certain threshold conditions must be satisfied before the
Commissioner will consider a request for relief under section
6015(f). See Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448.
Respondent does not contend that petitioner fails to satisfy
these threshold conditions for the year here under consideration,
and we focus our attention on other parts of the controlling
revenue procedure.
As in this case, if the requesting spouse satisfies the
threshold conditions of Rev. Proc. 2000-15, sec. 4.01, and relief
is unavailable under Rev. Proc. 2000-15, sec. 4.02, the
Commissioner looks to Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B.
at 448, to determine whether the taxpayer should be granted
equitable relief.
Section 4.03 of the revenue procedure provides a partial
list of positive and negative factors that the Commissioner is to
take into account when considering whether to grant an individual
full or partial equitable relief under section 6015(f). Rev.
Proc. 2000-15, sec. 4.03(1) lists the following six factors
weighing in favor of granting relief for an unpaid liability:
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