Robert L. Beck - Page 22

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          276, 287-292 (2000); see also Fernandez v. Commissioner, 114 T.C.           
          324, 328-332 (2000) (Tax Court has authority in “stand alone”               
          petition filed pursuant to section 6015(e)(1)(A) to review denial           
          of relief under section 6015(f)).  For the same reasons discussed           
          in Butler v. Commissioner, supra, we conclude that in this                  
          deficiency proceeding we have authority to review respondent’s              
          denial of equitable relief under the last sentence of section               
               Consistent with our enunciated standard of review for                  
          respondent’s denial of equitable relief under section 6015(f),              
          see Fernandez v. Commissioner, supra at 331; Butler v.                      
          Commissioner, supra at 291-293, we review the Commissioner’s                
          denial of equitable relief under section 66(c) for abuse of                 
               Mrs. Beck has not established that respondent abused his               
          discretion in refusing her request for equitable relief.  As                
          previously discussed, the record indicates that Mrs. Beck was               
          involved in Dr. Beck’s dental practice, was aware of the dental             
          practice income, and benefited substantially therefrom.  The                
          record is devoid of evidence that she was unaware of the Schedule           
          E income.  Moreover, Mrs. Beck has failed to establish that she             
          would suffer economic hardship if the relief were not granted.              
          Finally, by persistently failing to comply with the Rules and               
          Orders of this Court and by failing to cooperate with respondent            

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