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affd. 282 F.3d 326 (5th Cir. 2002). Respondent’s denial of
equitable relief is reviewed under an abuse of discretion
standard. Cheshire v. Commissioner, supra at 198; Butler v.
Commissioner, 114 T.C. at 292.
In Rowe I, we held that respondent abused his discretion in
denying petitioner relief under section 6015(f) for the portions
of the capital gains, mortgage interest, and charitable
contributions that were allocable to her. Additionally, we held
that respondent abused his discretion in denying equitable relief
for the remaining disputed additions to tax and penalties.
a. Items Allocable to Petitioner
In deciding whether petitioner was entitled to relief under
section 6015(f) for the portions of the capital gains, mortgage
interest, and charitable contributions allocable to her, we
reviewed the factors listed in Rev. Proc. 2000-15, 2000-5 I.R.B.
447, the Internal Revenue Service’s published guidelines on when
equitable relief should be granted. We discussed various
factors, including petitioner’s knowledge of the items giving
rise to the deficiencies and of respondent’s examination, the
circumstances surrounding her role in the tax reporting process,
her past and current financial situation, and the extent to which
she benefited from the items giving rise to the deficiencies. We
found that compelling reasons existed for respondent to grant
petitioner equitable relief. Consequently, we held that
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