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6015(f) for abuse of discretion.5 Butler v. Commissioner, 114
T.C. 276, 292 (2000). Petitioner bears the burden of proving
that respondent abused respondent’s discretion in denying that
relief. See Jonson v. Commissioner, 118 T.C. 106, 125 (2002).
Section 6015(f) grants respondent discretion to relieve an
individual who files a joint return from joint and several
liability with respect to that return. That section provides:
SEC. 6015(f). Equitable Relief.--Under procedures
prescribed by the Secretary, if--
(1) taking into account all the facts and
circumstances, it is inequitable to hold the indi-
vidual liable for any unpaid tax or any deficiency
(or any portion of either); and
(2) relief is not available to such individual
under subsection (b) or (c),
the Secretary may relieve such individual of such
liability.
In the instant case, the parties agree that relief is not avail-
able to petitioner under section 6015(b) or (c), thereby satisfy-
ing section 6015(f)(2).
As directed by section 6015(f), respondent has prescribed
procedures in Rev. Proc. 2000-15, 2000-1 C.B. 447 (Revenue
Procedure 2000-15), to be used in determining whether an individ-
ual qualifies for relief under that section. Section 4.01 of
5The Court’s jurisdiction in this case is dependent upon
sec. 6015(e)(1). See Ewing v. Commissioner, 118 T.C. __, __
(2002); Fernandez v. Commissioner, 114 T.C. 324, 330-331 (2000);
Butler v. Commissioner, 114 T.C. 276, 289-290 (2000).
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