- 6 - section 6015(b). We next address whether petitioner is eligible for relief under section 6015(c). Section 6015(c) provides for allocation of tax liability between the joint filers. Petitioner received two Forms W-2 for taxable year 1995, one of which was omitted from the 1995 tax return. Thus, the deficiency for taxable year 1995 arose from the omission of petitioner’s income. On these facts, we conclude that any allocation of tax liability would be to petitioner. Accordingly, we sustain respondent’s determination that petitioner is ineligible for relief under section 6015(c). Finally, we address whether petitioner is eligible for relief under section 6015(f). Section 6015(f) provides for equitable relief, at the Secretary’s discretion, if relief under section 6015(b) and (c) is not available. Thus, we review respondent’s denial of equitable relief under an abuse of discretion standard. Butler v. Commissioner, 114 T.C. 276, 292 (2000). Petitioner bears the burden of proving that respondent abused his discretion in denying equitable relief under section 6015(f). Jonson v. Commissioner, 118 T.C. 106, 125 (2002), affd. 353 F.3d 1181 (10th Cir. 2003). Rev. Proc. 2000-15, 2000-1 C.B. 447, describes the procedures for determining eligibility for equitable relief underPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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