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(investment in Hoyt partnership was attributable to the taxpayer
requesting section 6015 relief because she was a partner in the
Hoyt partnership). Accordingly, we conclude that petitioner is
not entitled to relief pursuant to section 6015(b).
B. Relief Under Section 6015(f)
Respondent argues that he did not abuse his discretion in
denying petitioner equitable relief under section 6015(f).
Respondent’s denial of relief is reviewed under an abuse of
discretion standard. Cheshire v. Commissioner, 115 T.C. 183, 198
(2000), affd. 282 F.3d 326 (5th Cir. 2002); Butler v.
Commissioner, 114 T.C. 276, 292 (2000). Our review is not
limited to respondent’s administrative record. Ewing v.
Commissioner, 122 T.C. ___ (2004).
As directed by section 6015(f), the Commissioner prescribed
procedures in Rev. Proc. 2000-15, 2000-1 C.B. 447,10 that
respondent uses to determine whether an individual qualifies for
relief under section 6015(f).
In this case, none of the six factors in Rev. Proc. 2000-15,
2000-1 C.B. 447, weighing in favor of granting relief are
10 We note that Rev. Proc. 2003-61, 2003-32 I.R.B. 296
(Aug. 11, 2003), superseded Rev. Proc. 2000-15, 2000-1 C.B. 447.
Rev. Proc. 2003-61, sec. 6, 2003-32 I.R.B. at 299. The new
revenue procedure, however, is effective for requests for relief
filed on or after Nov. 1, 2003. Id. Accordingly, it is
inapplicable to the case at bar.
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