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tax items. See Hopkins v. Commissioner, 121 T.C. at 77.
Consequently, the understatement of tax on the first amended
joint return and the 1992-1994 interest liability that resulted
from that understatement are attributable to petitioner.
Based on our examination of the facts and circumstances in
this case, many of the factors in Rev. Proc. 2000-15, sec. 4.03,
2000-1 C.B. at 448, are neutral. With respect to the factors
that are not neutral, those weighing against granting petitioner
relief outweigh those weighing in favor of granting her relief.
Accordingly, we conclude that respondent did not abuse his
discretion by acting arbitrarily, capriciously, or without sound
basis in fact in denying petitioner’s request for equitable
relief under section 6015(f).
Conclusion
We hold that respondent did not abuse his discretion in
denying petitioner relief from joint and several liability under
section 6015. We have considered the arguments of the parties
that were not specifically addressed in this opinion. Those
arguments are either without merit or irrelevant to our decision.
To reflect the foregoing,
Decision will be entered
for respondent.
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