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Petitioner concedes that he is not eligible for relief under
section 6015(b) or (c). Petitioner has instead requested
equitable relief under section 6015(f). Except as otherwise
provided in section 6015, petitioner bears the burden of proof.
Alt v. Commissioner, 119 T.C. 306, 311 (2002); Jonson v.
Commissioner, 118 T.C. 106, 113 (2002). We review the
determination to deny relief under an abuse of discretion
standard. See Washington v. Commissioner, 120 T.C. 137, 146
(2003); Cheshire v. Commissioner, 115 T.C. 183, 198 (2000), affd.
282 F.3d 326 (5th Cir. 2002); Butler v. Commissioner, 114 T.C.
276, 291-292 (2000). Petitioner must show that respondent’s
actions in denying relief were arbitrary, capricious, or without
sound basis in fact. Jonson v. Commissioner, supra at 125.
As directed by section 6015(f), the Commissioner has
prescribed procedures to determine whether a taxpayer qualifies
for relief from joint and several liability. These procedures
are set forth in Rev. Proc. 2000-15, 2000-1 C.B. 447. This Court
has upheld the use of these procedures in reviewing a negative
determination. See Washington v. Commissioner, supra at 147;
Jonson v. Commissioner, supra at 125. Rev. Proc. 2000-15, sec.
4.01, 2000-1 C.B. at 448, lists seven conditions (threshold
conditions) that must be satisfied before the Commissioner will
consider a request for relief under section 6015(f). Respondent
concedes that petitioner satisfies the seven threshold conditions
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