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the Secretary may relieve such individual of such
liability.
Pursuant to the discretionary authority granted in section
6015(f), respondent has prescribed procedures, set forth in Rev.
Proc. 2000-15, 2000-1 C.B. 447, for determining whether a spouse
qualifies for equitable relief from joint and several liability.
We have previously applied Rev. Proc. 2000-15, supra, in
considering equitable relief requests pursuant to section
6015(f). See, e.g., Jonson v. Commissioner, 118 T.C. 106, 125-
126 (2002), affd. 353 F.3d 1181 (10th Cir. 2003). The record
demonstrates that respondent applied Rev. Proc. 2000-15, supra,
to evaluate petitioner’s application for equitable relief in the
instant case.
We review respondent’s denial of petitioner’s claim for
equitable relief pursuant to section 6015(f) for abuse of
discretion. Butler v. Commissioner, 114 T.C. 276, 291-292
(2000). Consequently, we decide in the instant case whether
respondent acted arbitrarily, capriciously, or without sound
basis in fact in denying the requested relief. Jonson v.
Commissioner, supra at 125. Petitioner bears the burden of proof
as to whether respondent’s denial of such relief was an abuse of
discretion. See Rule 142(a). We are not limited to matters
contained in respondent’s administrative record when deciding the
issue. Ewing v. Commissioner, 122 T.C. 32, 35-44 (2004).
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