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6015(b) or (c) is premised on the existence of a deficiency for
the year for which relief is sought. Sec. 6015(b)(1)(D), (c)(1);
see H. Conf. Rept. 105-599, at 252-254 (1998), 1998-3 C.B. 747,
1006-1008. Consequently, if there is no deficiency for the year
for which relief is sought, relief from joint and several
liability is not available under either subsection. See
Washington v. Commissioner, 120 T.C. 137, 146-147 (2003); see
also Hopkins v. Commissioner, 121 T.C. 73, 88 (2003); Block v.
Commissioner, 120 T.C. 62, 65-66 (2003); Ewing v. Commissioner,
118 T.C. 494, 497, 498 n.4 (2002); cf. sec. 6015(e)(1). In this
case, petitioner seeks relief from additions to tax and interest
that respondent determined with respect to the tax liabilities
reported on the joint income tax returns for 1990 through 1995
rather than from deficiencies for those years. Accordingly, no
relief is available to petitioner under section 6015(b) or (c).
If relief is not available under either section 6015(b) or
(c), an individual may seek equitable relief under section
6015(f). Sec. 6015(f)(2). Section 6015(f) permits relief from
joint and several liability where “it is inequitable to hold the
individual liable for any unpaid tax or any deficiency (or any
portion of either)”. Sec. 6015(f)(1). Equitable relief under
section 6015(f) is granted at the Commissioner’s discretion.
We review the Commissioner’s determination to deny equitable
relief under section 6015(f) using an abuse of discretion
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