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jurisdiction to determine whether equitable relief is available
to petitioner for underpayment of tax shown on a joint return.
Ewing v. Commissioner, supra at 502.5
Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. 447, 448,
prescribes guidelines or factors that will be considered in
determining whether an individual qualifies for equitable relief
under section 6015(f). This Court has upheld the use of the
guidelines specified in Rev. Proc. 2000-15, supra, and has
analyzed the factors listed therein, in reviewing the
Commissioner's negative determinations under section 6015(f).
See, e.g., Washington v. Commissioner, supra at 147-152. Rev.
Proc. 2000-15, sec. 4.01, 2000-1 C.B. 447, 448, lists seven
threshold conditions that must be satisfied before the
Commissioner will consider a request for equitable relief under
section 6015(f). Respondent concedes that petitioner satisfies
the threshold conditions in this case. As discussed earlier, we
have found that petitioner did file a joint return. Therefore,
petitioner meets all the threshold requirements under Rev. Proc.
2000-15, supra.
Once petitioner has satisfied the threshold requirements,
Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, provides that,
in cases where a liability reported on a joint return is unpaid,
relief under section 6015(f) will ordinarily be granted if three
5Respondent continues to contest our jurisdiction to review
sec. 6015(f) claims in this case.
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