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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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