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Krasner’s credibility in reaching our findings and conclusions in
this case.
We turn now to the issue presented under section 6015(f).
As directed by that section, respondent has prescribed procedures
in Rev. Proc. 2000-15, 2000-1 C.B. 447 (Revenue Procedure
2000-15)23 that are to be used in determining whether it would be
inequitable to find the requesting spouse liable for part or all
of the 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 re-
questing 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
23We note that Rev. Proc. 2003-61, 2003-2 C.B. 296 (Revenue
Procedure 2003-61), superseded Revenue Procedure 2000-15.
Revenue Procedure 2003-61 is effective for requests for relief
under sec. 6015(f) which were filed on or after Nov. 1, 2003, and
for requests for such relief which were pending on, and for which
no preliminary determination letter had been issued as of, that
date. Id. sec. 7, 2003-2 C.B. at 299. Revenue Procedure 2003-61
is not applicable in the instant case. That is because
(1) petitioner filed her request for relief under sec. 6015(f)
(viz, petitioner’s Form 8857) on Jan. 15, 2001, and (2) the IRS
issued preliminary determinations on Aug. 31, and Oct. 26, 2001,
respectively (viz, respondent’s August 31, 2001 letter to peti-
tioner and respondent’s October 26, 2001 letter to petitioner)
with respect to such request for relief.
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