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standard. Butler v. Commissioner, supra at 287-292. Under this
standard of review, we defer to the Commissioner’s determination
unless it is arbitrary, capricious, or without sound basis in
fact. Jonson v. Commissioner, 118 T.C. 106, 125 (2002) (citing
Butler v. Commissioner, supra at 292; Pac. First Fed. Sav. Bank
v. Commissioner, 101 T.C. 117, 121 (1993)), affd. 353 F.3d 1181
(10th Cir. 2003). The question of whether the Commissioner’s
determination was arbitrary, capricious, or without sound basis
in fact is a question of fact. Cheshire v. Commissioner, 115
T.C. 183, 198 (2000), affd. 282 F.3d 326 (5th Cir. 2002). We are
not limited to the matters contained in the Commissioner’s
administrative record when deciding this question. Ewing v.
Commissioner, 122 T.C. 32, 35–44 (2004). Petitioner bears the
burden of proving that respondent abused respondent’s discretion
in denying her relief under section 6015(f). Washington v.
Commissioner, supra at 146; Jonson v. Commissioner, supra at 125.
Petitioner’s brief contains bold and general rhetoric and no
analysis of the evidence or of the applicable authorities,
notwithstanding the Court’s specific direction that her brief
address section 6015(f) and the relevant factors.
As directed by section 6015(f), the Commissioner has
prescribed procedures to use in determining whether a relief-
seeking spouse qualifies for relief under that subsection.
Notice 98-61, 1998-2 C.B. 756, provided interim guidance for
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