- 15 -
1991. We review that denial of relief for abuse of discretion.
Butler v. Commissioner, supra at 291-292. Ms. Collier bears the
burden of proving that respondent abused respondent’s discretion
in denying her relief under section 6015(f). See Jonson v.
Commissioner, 118 T.C. 106, 125 (2002).
As directed by section 6015(f),11 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
Revenue Procedure 2000-15 lists seven conditions (threshold
conditions) that must be satisfied before the Internal Revenue
Service (Service) will consider a request for relief under
section 6015(f).12 If a requesting spouse satisfies all of the
11Sec. 6015(f) provides:
SEC. 6015. RELIEF FROM JOINT AND SEVERAL LIABILITY ON
JOINT RETURN
(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 individ-
ual under subsection (b) or (c),
the Secretary may relieve such individual of such
liability.
12Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. 448, provides:
(continued...)
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