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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
66(c).
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
discretion.
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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