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In the instant case, the parties agree that relief is not
available to petitioner under section 6015(b) or (c), thereby
satisfying section 6015(f)(2).20
We turn first to a dispute between the parties as to the
scope of the record upon which we should determine whether
respondent abused respondent’s discretion in denying petitioner
relief under section 6015(f). As we understand her position,
petitioner contends that that record should include not only the
information that petitioner presented to respondent during
respondent’s administrative consideration of petitioner’s request
for relief under section 6015(f) but also the additional informa-
tion (petitioner’s additional information) that petitioner
presented at trial and that is part of the record in this case.
Respondent counters that the Court should determine whether
respondent abused respondent’s discretion in denying petitioner
relief under section 6015(f) only on the basis of the information
that petitioner presented to respondent during respondent’s
administrative consideration of her request for that relief.21
20The Court’s jurisdiction in this case is dependent upon
sec. 6015(e)(1). See Ewing v. Commissioner, 118 T.C. 494, 496-
497 (2002), Fernandez v. Commissioner, 114 T.C. 324, 330-331
(2000); Butler v. Commissioner, supra at 289-290.
21In this connection, respondent objected at trial, inter
alia, to certain evidence as irrelevant and immaterial to the
issue of whether respondent abused respondent’s discretion in
denying petitioner equitable relief under sec. 6015(f). We
overruled respondent’s objections and indicated that, in deter-
(continued...)
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