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respect to liability for deficiencies. Sec. 6015(c)(1). In
general terms, and for purposes of this case, both an
“understatement” and a “deficiency” are equal to the amount of
tax required to be shown on a return less the amount of tax
actually shown on the return. Secs. 6015(b)(3), 6662(d)(2)(A),
6211(a). The unpaid tax liabilities in this case result from
amounts shown as due on the returns filed by petitioner and Mr.
Rooks. These underpayments have been assessed by respondent.
Because respondent does not assert that the amounts of tax shown
on petitioner’s returns as filed (and as reduced by the amended
returns) were less than the amounts required to be shown thereon,
there is neither an understatement nor a deficiency in this case,
making section 6015(b) and (c) inapplicable.
The remaining avenue for relief under section 6015 is the
equitable relief which may be afforded by section 6015(f). This
relief is available to taxpayers who are not otherwise entitled
to section 6015 relief if, taking into account all the facts and
circumstances, it is inequitable to hold the taxpayer liable for
any unpaid tax or deficiency (or portion thereof). Sec.
6015(f)(1) and (2). Section 6015(f) relief is available to
petitioner--because that provision applies to any unpaid tax
liability--and this Court may review respondent’s denial of such
relief. Ewing v. Commissioner, 118 T.C. 494 (2002).
Equitable relief under section 6015(f) is discretionary, and
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