Ruthe G. Ohrman - Page 30

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          has satisfied the threshold requirements of Rev. Proc. 2000-15,             
          sec. 4.01.                                                                  
               Because we decided that petitioner received a transfer of              
          disqualified assets from Mr. Ohrman, we conclude that petitioner            
          does not meet all seven of the threshold conditions of Rev. Proc.           
          2000-15, sec. 4.01.  Accordingly, we conclude that respondent did           
          not abuse his discretion by acting arbitrarily, capriciously, or            
          without sound basis in fact in denying petitioner’s request for             
          equitable relief under section 6015(f).                                     
               We hold that respondent did not err in denying petitioner              
          relief from joint and several liability under section 6015 with             
          respect to the joint return filed with Mr. Ohrman for 1999.  We             
          have considered the arguments of the parties not specifically               
          addressed in this opinion.  Those arguments are either without              
          merit or irrelevant to our decision.                                        
               To reflect the foregoing,                                              

                                                   Decision will be entered           
                                             for respondent.                          

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