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examination that he did not suffer any verbal or physical abuse
from Ms. Cullen. Thus, the Court concludes that petitioner knew
or had reason to know that there was an understatement of tax on
the 1999 joint tax return; that it was not signed under duress;
and that section 6015(c) relief is not available. See Jonson v.
Commissioner, 118 T.C. at 115.
IV. Relief Under Section 6015(f)
This Court has jurisdiction to review the denial of
equitable relief. Fernandez v. Commissioner, 114 T.C. 324, 328-
329 (2000); Butler v. Commissioner, supra at 292. The Court’s
precedent indicates it reviews respondent’s denial of relief to
determine whether respondent abused his discretion by acting
arbitrarily, capriciously or without sound basis in fact. Ewing
v. Commissioner, 122 T.C. 32, 39 (2004); Butler v. Commissioner,
supra at 287-292. Petitioner has failed to make that showing
here.
Section 6015(f) provides as follows:
SEC. 6015(f). Equitable Relief.--Under procedures
prescribed by the Secretary, if--
(1) taking into account all the facts and
circumstances, it is inequitable to hold the
individual liable for any unpaid tax or any
deficiency (or any portion of either); and
(2) relief is not available to such
individual under subsection (b) or (c), the
Secretary may relieve such individual of such
liability.
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