- 20 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
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