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296, modifying and superseding Rev. Proc. 2000-15, 2000-1 C.B.
447.
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 relief under section 6015(f).
Respondent concedes that petitioner satisfies each of the seven
threshold conditions.
A requesting spouse who satisfies all of the applicable
threshold conditions may be relieved of all or part of the
liability under section 6015(f), if, taking into account all the
facts and circumstances, the IRS determines that it would be
inequitable to hold the requesting spouse liable for the income
tax liability. Rev. Proc. 2003-61, sec. 4.01.
To qualify for relief under Rev. Proc. 2003-61, sec. 4.02,
2003-2 C.B. at 298, the requesting spouse must: (1) No longer be
married to, be legally separated from, or not have been a member
of the same household as the nonelecting spouse at any time
during the 12-month period ending on the date of the request for
relief; (2) have had no knowledge or reason to know when he or
she signed the return that the nonelecting spouse would not pay
the tax liability; and (3) suffer economic hardship if relief is
not granted. See Rev. Proc. 2003-61, sec. 4.02(1), 2003-2 C.B.
at 298.
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