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affd. 353 F.3d 1181 (10th Cir. 2003). A taxpayer bears the
burden of proving that the Commissioner abused his discretion.
Washington v. Commissioner, 120 T.C. 137, 146 (2003).
Pursuant to section 6015(f), the Commissioner has prescribed
procedures to determine whether a taxpayer qualifies for relief
under that section. Those procedures are set forth in Rev. Proc.
2000-15, 2000-1 C.B. 447. This Court has upheld the use of those
procedures in reviewing a negative determination for relief from
joint and several liability. Jonson v. Commissioner, supra.
Section 4.01 of Rev. Proc. 2000-15, 2000-1 C.B. at 448,
lists seven threshold conditions that must be satisfied before
the Commissioner will consider a request for relief under section
6015(f). If the threshold conditions are satisfied, relief may
be granted under section 4.02 of Rev. Proc. 2000-15, which
applies to relief from liability that is reported on a joint
return but that remains unpaid. If that section does not apply,
the Commissioner looks to section 4.03 of Rev. Proc. 2000-15 to
determine whether the taxpayer should be granted relief. In this
case, respondent does not assert that petitioner has failed to
meet any of the threshold requirements of section 4.01 of Rev.
Proc. 2000-15. Because the liability in question was not
reported on the joint return, section 4.02 of Rev. Proc. 2000-15
is not applicable in this case. We therefore turn to section
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