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the corporation was not reimbursed for personal use of the yacht.
To the extent of these items, therefore, respondent has proven
that petitioner had actual knowledge disqualifying her from
relief under section 6015(c).
Aside from her overall denials and disclaimers, petitioner
has given us no reason to reject respondent’s allocations of
amounts for which petitioner is not entitled to relief under
section 6015(c). Except as set forth above with respect to
transfers before September 5, 1989, she is not entitled to relief
beyond the concessions made by respondent in the posttrial brief.
Section 6015(f) Analysis
Section 6015(f) provides an additional opportunity for
relief to those taxpayers who do not otherwise meet the
requirements of subsection (b) or (c) of section 6015.
Specifically, section 6015(f) gives respondent the discretion to
grant equitable relief from joint and several liability if
“taking into account all the facts and circumstances, it is
inequitable to hold the individual liable for any unpaid tax”.
We have jurisdiction to review respondent’s denial of
petitioner’s request for equitable relief under section 6015(f).
Jonson v. Commissioner, 118 T.C. 106, 125 (2002), affd. 353 F.3d
1181 (10th Cir. 2003); Butler v. Commissioner, 114 T.C. at 292.
We review such denial of relief to decide whether respondent
abused his discretion by acting arbitrarily, capriciously, or
without sound basis in fact. Jonson v. Commissioner, supra at
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