-8-
resulting self-employment tax deduction is allocable both to him
and Hawthorne. We disagree. The self-employment tax deduction
resulting from the self-employment tax due to Hawthorne’s self-
employment income from Medi-Task is allocable to Hawthorne under
the separate return rule for reasons discussed in paragraph A,
above.
C. Whether Respondent’s Determination That Hawthorne Is
Entitled to Relief Under Section 6015(f) Was an Abuse of
Discretion
After we issued our opinion in these cases at Charlton v.
Commissioner, 114 T.C. 333 (2000), respondent determined that
Hawthorne was entitled to equitable relief under section 6015(f)
for the deficiency in income tax attributable to the denied
deductions for the rental cabins and the deficiency in self-
employment tax attributable to improper netting due to the fact
that Charlton netted Medi-Task income and expenses with rental
cabin expenses. Charlton disagrees with respondent’s
determination.
We apply an abuse of discretion standard to review the
Commissioner’s determinations under section 6015(f). See
Cheshire v. Commissioner, 115 T.C. 183, 199 (2000); Fernandez v.
Commissioner, 114 T.C. 324, 332 (2000); Butler v. Commissioner,
114 T.C. 276, 291-293 (2000). Charlton contends: (1) The
improper characterization of costs for the rental cabins and
self-employment tax netting errors are partially attributable to
Hawthorne; (2) Hawthorne knew or had reason to know of the
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