Judith A. Madden - Page 12

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              Petitioner does not satisfy all of the elements because she             
         remains married to, and is not separated from, Mr. Sturges.                  
         Consequently, she does not qualify for relief under Rev.                     
         Proc. 2000-15, sec. 4.02(1).                                                 
              In cases where the threshold conditions have been satisfied             
         but the requesting spouse does not qualify for relief under Rev.             
         Proc. 2000-15, sec. 4.02(1), equitable relief may be granted                 
         under section 6015(f) if, taking into account all facts and                  
         circumstances, it is inequitable to hold the requesting spouse               
         liable.  Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448.                  
              Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448-449, lists            
         positive and negative factors that the Commissioner will take                
         into account in determining whether to grant equitable relief                
         under section 6015(f).  Rev. Proc. 2000-15, sec. 4.03(1), 2000-1             
         C.B. at 448-449, lists the following six factors as weighing in              
         favor of granting relief for an unpaid liability:  (1) The                   
         requesting spouse is separated or divorced from the nonrequesting            
         spouse; (2) the requesting spouse will suffer economic hardship              
         if relief is denied; (3) the requesting spouse was abused by the             
         nonrequesting spouse; (4) the requesting spouse did not know or              
         have reason to know at the time the return was signed that the               
         reported liability would be unpaid; (5) the nonrequesting spouse             
         has a legal obligation pursuant to a divorce decree or agreement             
         to pay the unpaid liability; and (6) the unpaid liability is                 






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