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all the facts and circumstances, it is inequitable to hold the
other spouse liable for the deficiency in tax for such taxable
year attributable to such substantial understatement".
We have consistently applied a "facts and circumstances"
analysis in considering the application of former section
6013(e)(1)(D). See Terzian v. Commissioner, 72 T.C. 1164, 1170
(1979); French v. Commissioner, T.C. Memo. 1996-38; Bouskos v.
Commissioner, T.C. Memo. 1987-574. In Kistner v. Commissioner,
T.C. Memo. 1995-66, on remand from the Court of Appeals for the
Eleventh Circuit, we discussed the particular standards to be
applied when deciding the appropriate relief pursuant to section
6013(e)(1)(D). Accordingly, we are well equipped to decide
whether it was an abuse of discretion for respondent to deny
relief to petitioner under section 6015(f). See Local 1219, Am.
Fed. of Gov. Employees v. Donovan, 683 F.2d 511, 516 (D.C. Cir.
1982) ("This limited determination is one which courts are well-
equipped to make.").7
On the basis of the foregoing, we conclude that we have the
authority to review respondent's denial of petitioner's claim for
equitable relief pursuant to section 6015(f). We discuss below
whether it was an abuse of discretion for respondent to deny
petitioner's equitable relief claim.
7 We note that respondent in Rev. Proc. 2000-15, 2000-5 I.R.B.
447, announced certain standards by which respondent will
evaluate an equitable relief request.
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