Deborah Ann Puckett - Page 8

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          of equitable relief under section 6015(f) was an abuse of                   
          discretion.  Rule 142(a); Alt v. Commissioner, 119 T.C. 306, 311            
          (2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004); Jonson v.                  
          Commissioner, 118 T.C. 106, 113 (2002), affd. 353 F.3d 1181 (10th           
          Cir. 2003).  Petitioner must demonstrate that respondent                    
          exercised his discretion arbitrarily, capriciously, or without              
          sound basis in fact or law.  Jonson v. Commissioner, supra at               
          125; Woodral v. Commissioner, 112 T.C. 19, 23 (1999).                       
               Section 6015(f) provides:                                              
                    SEC. 6015(f).  Equitable Relief.--Under procedures                
               prescribed by the Secretary, if--                                      
                         (1) taking into account all the facts                        
                    and circumstances, it is nequitable 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. 447.4  The requesting spouse must satisfy seven conditions           

               4  Rev. Proc. 2003-61, 2003-2 C.B. 296, which supersedes               
                                                             (continued...)           





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