- 20 - amount greater than that conceded by respondent. Petitioner's final claim for relief is under section 6015(f). That provision allows the Secretary to relieve a spouse of liability if, taking into account all the facts and circumstances, it is inequitable to hold the spouse liable for any unpaid tax or deficiency and relief is otherwise not available under section 6015(b) or (c). Cheshire v. Commissioner, 115 T.C. 183, 198 (2000). This Court's review under section 6015(f) is limited to whether there was an abuse of discretion by the Secretary in denying relief. Cheshire v. Commissioner, supra at 198; Butler v. Commissioner, 114 T.C. 276, 292 (2000). On the basis of all the facts and circumstances discussed earlier, petitioner has not established that there was an abuse of discretion by respondent in denying her claim for relief under section 6015(f). Reviewed and adopted as the report of the Small Tax Division. Decision will be entered under Rule 155.7 7 For the year 1993, respondent determined that, because of the income and expense adjustments, $3,936 of Social Security benefits received by petitioner and Mr. Gurr is includable in their gross income. It appears to the Court that both Mr. Gurr and petitioner received Social Security benefits during 1993; (continued...)Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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