- 13 - We find that Mrs. Haggart had reason to know of the understatements of tax. As a result of our conclusion, we need not determine whether Mrs. Haggart satisfies the other requirements, and hold that Mrs. Haggart is not eligible for relief from joint and several liability under section 6015(b). B. Section 6015(f) Relief Section 6015(f) provides: SEC. 6015(f) Equitable Relief.–-Under procedures prescribed by the Secretary, if-- (1) 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); and (2) relief is not available to such individual under subsection (b) or (c), the Secretary may relieve such individual of such liability. To prevail, Mrs. Haggart must show that respondent’s denial of equitable relief under section 6015(f) was an abuse of discretion. Jonson v. Commissioner, 118 T.C. 106, 125 (2002); Cheshire v. Commissioner, supra at 198; Butler v. Commissioner, 114 T.C. 276, 292 (2000). As directed by section 6015(f), respondent prescribed procedures to use in determining whether the requesting spouse qualifies for relief under section 6015(f). Those procedures are found in Rev. Proc. 2000-15, 2000-1 C.B. 447.11 The revenue procedure includes partial lists of positive and negative factors to be considered, including whether the 11 Rev. Proc. 2000-15, sec. 3, 2000-1 C.B. 447, 448, is applicable for any liability for tax arising on or before July 22, 1998, that was unpaid on that date.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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