SECTION 1. PURPOSE

This revenue procedure provides guidance for taxpayers seeking equitable relief from federal tax liability under § 6015(f) or 66(c) of the Internal Revenue Code (a “requesting spouse”). Section 4.01 of this revenue procedure provides the threshold conditions that must be satisfied for any request for equitable relief to be considered. Section 4.02 of this revenue procedure sets forth the conditions under which relief under § 6015(f) will ordinarily be granted. Section 4.03 of this revenue procedure provides a partial list of factors to be considered in determining whether it would be inequitable to hold a requesting spouse jointly and severally liable for a liability that was properly reported but not paid where the conditions of section 4.02 are not met, or for a deficiency. The factors in section 4.03 will also be used to determine whether equitable relief should be granted under § 66(c).