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reviewing the IRS’s denial of relief. See Washington v.
Commissioner, supra at 147-152; Rev. Proc. 2003-61, 2003-2 C.B.
296, modifying and superseding Rev. Proc. 2000-15, 2000-1 C.B.
447.
Rev. Proc. 2003-61, Sec. 4.01: Seven Threshold Conditions for
Relief
Rev. Proc. 2003-61, sec. 4.01, 2003-2 C.B. at 297, begins
with a list of seven threshold conditions that a taxpayer must
satisfy in order to qualify for equitable relief. The Court will
not recite them. Respondent concedes that petitioner satisfies
the threshold requirements for 1999. The Court finds that
petitioner satisfies the threshold requirements with respect to
the items that are not attributable to her for 2000 as determined
by the Appeals officer handling the appeal. To the extent that
the unpaid liability consists of items attributable to
petitioner, respondent did not abuse his discretion in denying
relief because she does not satisfy the requirement: “the
liability from which the requesting spouse seeks relief is
attributable to an item” of the other spouse. See Rev. Proc.
2003-61, sec. 4.01(7), 2003-2 C.B. at 297.
Rev. Proc. 2003-61, Sec. 4.02: Circumstances Ordinarily Allowing
for Relief
Where the requesting spouse satisfies the threshold
conditions of Rev. Proc. 2003-61, sec. 4.01, Rev. Proc. 2003-61,
sec. 4.02, 2003-2 C.B. at 298, sets forth the circumstances in
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