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sets forth the threshold conditions that must be satisfied before
the Commissioner will consider a request for equitable relief
under section 6015(f). Respondent does not dispute that
petitioner has satisfied those threshold conditions.
A requesting spouse satisfying all the applicable threshold
conditions may be relieved of all or part of the liability under
section 6015(f) if, taking into account all the facts and
circumstances, the IRS determines that it would be inequitable to
hold the requesting spouse liable for the liability. Rev. Proc.
2000-15, sec 4.01, supra at 448.
Rev. Proc. 2000-15, sec. 4.03(1) and (2), 2001-1 C.B. at
448-449, sets forth six positive and six negative factors that
are to be considered in determining whether to grant relief. The
revenue procedure makes clear that no single factor is to be
determinative in any particular case, that all factors are to be
considered and weighed appropriately, and that the list of
factors is not intended to be exhaustive.
The knowledge or reason to know factor, the economic
hardship factor, and the legal obligation to pay factor in Rev.
Proc. 2000-15, sec. 4.03(2)(b), (d), and (f), 2000-1 C.B. at 449,
respectively, are the opposites of the knowledge or reason to
know factor, the economic hardship factor, and the legal
obligation to pay factor in Rev. Proc. 2000-15, sec. 4.03(1)(d),
(b), and (e), respectively. The attribution factor in Rev. Proc.
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