- 23 - 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),Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011