- 19 -
fact or law. See Jonson v. Commissioner, supra at 125; Woodral
v. Commissioner, 112 T.C. 19, 23 (1999).
Section 6015(f) provides:
(1) taking into account all the facts and
circumstances, it is inequitable to hold the
individual liable for any unpaid tax or any
deficiency (or any portion of either); and
(2) relief is not available to such
individual under subsection (b) or (c),
the Secretary may relieve such individual of such
liability.
As directed by section 6015(f), the Commissioner has
prescribed procedures to be used in determining whether the
requesting spouse qualifies for relief from joint and several
liability under section 6015(f). As applicable to the present
case, these procedures are set forth in Rev. Proc. 2000-15, 2000-
1 C.B. 447.6 The requesting spouse must satisfy seven conditions
(threshold conditions) before the Commissioner will consider a
6Rev. Proc. 2003-61, 2003-2 C.B. 296, which supersedes Rev.
Proc. 2000-15, 2000-1 C.B. 447, is effective for requests for
relief under sec. 6015(f) filed on or after Nov. 1, 2003, and for
requests for such relief pending on, and for which no preliminary
determination letter had been issued as of, that date. Rev.
Proc. 2003-61, sec. 7, 2003-2 C.B. at 299. Rev. Proc. 2003-61,
supra, is not applicable in this case because (1) petitioner
filed her request for relief on Aug. 9, 2002, and (2) respondent
issued a preliminary determination on May 23, 2003.
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