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which petitioner was sole owner at the time of trial) and has
resumed his medical practice, which is the couple’s primary
source of income. Petitioner “continues to enjoy the lifestyle
and financial security that are largely attributable to her
husband’s assets and income.” Von Kalinowski v. Commissioner,
supra; see Lauer v. Commissioner, T.C. Memo. 1994-579. On the
basis of all the evidence, we conclude that denial of relief from
joint and several liability will not result in economic hardship
for petitioner. There is no suggestion in the record of spousal
abuse or duress. These considerations support our conclusion
that it would not be inequitable to deny petitioner the requested
relief from joint and several liability.
Accordingly, we hold that petitioner is not entitled to
relief under section 6015(b).
IV. Relief Under Section 6015(f)
Petitioner contends that respondent abused his discretion in
denying her request for relief from joint and several liability
under section 6015(f).
Where relief is unavailable to an individual under section
6015(b), the Secretary may provide relief under section 6015(f)
if “taking into account all the facts and circumstances, it is
inequitable to hold the individual liable for any unpaid tax or
any deficiency (or any portion of either)”. Sec. 6015(f).
Essentially the same language appears in the equities test of
section 6015(b)(1)(D). Butler v. Commissioner, 114 T.C. at 291.
Having concluded, in light of all the facts and circumstances,
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