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3. Section 6015(f)
After we grant relief to petitioner under section 6015(c),
she may still have some liability for portions of the
deficiencies for 1982, 1983, and 1984 that are allocable to her
under section 6015(d). We will therefore consider her
eligibility for relief under section 6015(f). Under section
6015(f), the Secretary is authorized to grant equitable relief
where: (1) The taxpayer is not entitled to relief under section
6015(b) or (c), and (2) “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)”.
See Cheshire v. Commissioner, 282 F.3d at 338. We review for an
abuse of discretion the Commissioner’s decision not to grant
equitable relief. Butler v. Commissioner, 114 T.C. 276, 292
(2000).
The Far West Drilling deductions and the overstated NOL
carryforward deductions greatly reduced petitioner and Mr.
Hopkins’s joint tax liabilities in 1982, 1983, and 1984. In or
about those years, considerable amounts were spent to rebuild
petitioner’s house at 111 Diablo Drive. Petitioner was, and
still is, the sole owner of that residence, and she was the
person who received the most comfort and benefit from the use of
that residence before and after those years. The reduced tax
liabilities for 1982, 1983, and 1984 enhanced petitioner’s
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