Renee Trupin D'Aunay - Page 21

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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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