- 19 -
supra at 291. Further, the equitable factors we considered under
section 6015(b)(1)(D) are the same equitable factors we consider
under section 6015(f).13 As a result, we hold that respondent
did not abuse his discretion in denying petitioner relief under
section 6015(f) for taxable years 1982 to 1988.
In reaching our holdings, we have considered all arguments
made by the parties, and, to the extent not mentioned above, we
conclude they are irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
12(...continued)
roots in the equity test of former subparagraph 6013(e)(1)(D)
carried forward into subparagraph 6015(b)(1)(D).”), affg. T.C.
Memo. 2000-332.
13 The Commissioner has announced a list of factors in Rev.
Proc. 2000-15, sec. 4.03, 2000-1 C.B. 447, 448, that the
Commissioner will consider in deciding whether to grant equitable
relief under sec. 6015(f). The revenue procedure takes into
account factors such as marital status, economic hardship, and
significant benefit in determining whether relief will be granted
under sec. 6015(f). Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B.
at 448.
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