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petitioner is not entitled to relief under section 6015(b) or
(c). See sec. 6015(b)(1) and (c)(1); Washington v. Commissioner,
120 T.C. 137, 146-147 (2003). Therefore, our review is limited
to section 6015(f), which permits in certain circumstances relief
from joint and several liability for unpaid taxes. Ewing v.
Commissioner, 118 T.C. 494, 497 (2002).
Section 6015(f) permits the Secretary to relieve a spouse of
liability if, taking into account all the facts and
circumstances, it is inequitable to hold the spouse liable for
any unpaid tax or any deficiency (or any portion of either) and
relief is not available under section 6015(b) or (c). The denial
of equitable relief is reviewed under an abuse of discretion
standard. Washington v. Commissioner, supra at 146. In deciding
whether the determination was an abuse of discretion, we consider
evidence relating to all the facts and circumstances. Id. at
148.
Rev. Proc. 2000-15, 2000-1 C.B. 447, contains guidelines
that will be considered in determining whether an individual
qualifies for relief under section 6015(f).2 Rev. Proc. 2000-15,
sec. 4.01, 2000-1 C.B. at 448, lists seven threshold conditions
that must be satisfied before the Commissioner will consider a
2On Aug. 11, 2003, the Commissioner issued Rev. Proc. 2003-
61, 2003-32 I.R.B. 296, which supersedes Rev. Proc. 2000-15,
2000-1 C.B. 447, effective for requests for relief filed on or
after Nov. 1, 2003.
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