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Id. A requesting spouse must satisfy all seven threshold
conditions before respondent will consider his or her request for
equitable relief under section 6015(f). Id. We have upheld the
use of these procedures in reviewing a negative determination.
See Washington v. Commissioner, supra at 147; Jonson v.
Commissioner, supra at 125.
As indicated above with reference to section 6015(b),
considering the facts and circumstances in this case, we cannot
conclude that it would be inequitable to hold petitioner liable
for the deficiencies resulting from her filing joint returns with
Trupin for the years in issue. A fortiori, we cannot conclude
that denial of relief was an abuse of discretion, i.e.,
arbitrary, capricious, or without sound basis in fact. See Ewing
v. Commissioner, 122 T.C. 32, 39 (2004).
Petitioner’s predicament has resulted from the activities in
which she engaged with her former husband, Trupin, exacerbated by
her activities with her husband, D’Aunay.
(It may occur to the reader that petitioner could or should
make an offer in compromise under section 7122. Her refusal to
provide financial information to the IRS, however, also precludes
that avenue of relief.)
To take account of respondent’s concessions of the extent to
which petitioner may be relieved from liability under section
6015(c),
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