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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).
Conclusion
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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