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which is shown on the return, reduced by any rebate (within the
meaning of section 6211(b)(2)). Secs. 6015(b)(3), 6662(d)(2)(A).
Section 6015(c) allows a taxpayer who is eligible and so
elects to limit his or her liability to the portion of a
deficiency that is properly allocable to the taxpayer as provided
in section 6015(d). Sec. 6015(c)(1).
In the present case, there is neither an understatement of
tax, as required under section 6015(b), nor a deficiency, as
required under section 6015(c). Rather, there is an underpayment
of tax. The 1993 return filed by petitioner and Mr. Hyatt
reported tax due of $4,175, but they did not remit any payment
with their return. Accordingly, section 6015(b) and (c) cannot
apply. We sustain respondent’s determination that petitioner is
not entitled to relief from joint and several liability under
either section 6015(b) or (c).
2. Section 6015(f)
Since petitioner is not entitled to relief under section
6015(b) or (c), we consider whether petitioner qualifies for
relief under section 6015(f), after a trial de novo and using an
abuse of discretion standard. See Ewing v. Commissioner, supra
at 43-44; Fernandez v. Commissioner, supra at 328-329; Butler v.
Commissioner, supra at 287-292. Petitioner bears the burden of
proving that respondent’s denial of equitable relief under
section 6015(f) was an abuse of discretion. See Rule 142(a); Alt
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