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4.02, then Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. 447, 448-
449, sets forth guidelines or factors that the Commissioner will
consider in deciding claims for equitable relief under section
6015(f). Rev. Proc. 2000-15, sec. 4.03(1), 2000-1 C.B. at 448-
449, sets forth the following positive factors which weigh in
favor of granting equitable relief under section 6015(f):
(a) Marital status. The requesting spouse is
separated * * * or divorced from the nonrequesting
spouse.
(b) Economic hardship. The requesting spouse
would suffer economic hardship (within the meaning of
section 4.02(1)(c) of this revenue procedure) if relief
from the liability is not granted.
(c) Abuse. The requesting spouse was abused by
the nonrequesting spouse, but such abuse did not amount
to duress.
(d) No knowledge or reason to know. In the case
of a liability that was properly reported but not paid,
the requesting spouse did not know and had no reason to
know that the liability would not be paid. * * *
(e) Nonrequesting spouse's legal obligation. The
nonrequesting spouse has a legal obligation pursuant to
a divorce decree or agreement to pay the outstanding
liability. * * *
(f) Attributable to nonrequesting spouse. The
liability for which relief is sought is solely
attributable to the nonrequesting spouse.
Rev. Proc. 2000-15, sec. 4.03(2), 2000-1 C.B. at 449, sets
forth the following negative factors which weigh against granting
equitable relief under section 6015(f):
(a) Attributable to the requesting spouse. The
unpaid liability or item giving rise to the deficiency
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