- 48 -
economic hardship if relief were not granted. See sec. 301.6343-
1(b)(4), Proced. & Admin. Regs.; Rev. Proc. 2000-15, sec.
4.02(1)(c).
On the basis of the record as a whole in this case, we
cannot say that respondent abused his discretion by acting
arbitrarily, capriciously, or without sound basis in fact in
denying petitioner’s request for relief under section 6015(f).
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Last modified: May 25, 2011