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entitled to relief under section 6015(f) is an abuse of
discretion.
Charlton questions the qualifications of the revenue agent
who prepared the Form 886A, Explanation of Items, which detail
respondent’s reasons for granting Hawthorne relief under section
6015(f). However, there is no indication that the revenue agent
was unqualified, and respondent is not required to establish the
qualifications of the revenue agent who prepared the Form 886A.
See Greenberg’s Express v. Commissioner, 62 T.C. 324, 327 (1974).
Charlton states that he does not know what information the
revenue agent used to support the findings on the Form 886A, that
he did not have the opportunity to question witnesses or examine
evidence that the revenue agent considered, and that he did not
have the opportunity to rebut Hawthorne’s statements. However,
Charlton neither offered any evidence nor made any convincing
argument that respondent’s determination that Hawthorne was
entitled to relief under section 6015(f) was an abuse of
discretion. Similarly, he has not identified any new evidence
that he wishes to offer. See Rodman v. Commissioner, 542 F.2d
845, 860 (2d Cir. 1976) (unsupported allegations do not establish
an abuse of discretion), affg. in part, revg. in part on another
ground, and remanding T.C. Memo. 1973-277; United States v.
Marshall, 526 F.2d 1349, 1356 (9th Cir. 1975) (same).
At trial, Hawthorne contended that she was entitled to
relief under section 6015(b). To be entitled to relief under
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