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circumstances, 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,
are:
(a) At the time relief is requested, the request-
ing spouse is no longer married to, or is legally
separated from, the nonrequesting spouse, or has not
been a member of the same household as the
nonrequesting spouse at any time during the 12-month
period ending on the date relief was requested;
(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
(c) The requesting spouse will suffer economic
hardship if relief is not granted. For purposes of
this section, the determination of whether a requesting
spouse will suffer economic hardship will be made by
the Commissioner or the Commissioner's delegate, and
will be based on rules similar to those provided in
� 301.6343-1(b)(4) of the Regulations on Procedure and
Administration. [Rev. Proc. 2000-15, sec. 4.02(1),
2000-1 C.B. at 448.]
(We shall hereinafter refer to the elements set forth in section
4.02(1)(a), (b), and (c) of Revenue Procedure 2000-15 as the
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