- 30 - 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.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
Last modified: May 25, 2011