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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 under
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