Fredie Lynn Charlton - Page 10




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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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