Mary K. Malone - Page 6

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               With respect to the relief that she requests, petitioner               
          bears the burden of proof.  Alt v. Commissioner, 119 T.C. 306,              
          311 (2002); Jonson v. Commissioner, 118 T.C. 106, 113 (2002),               
          affd. 353 F.3d 1181 (10th Cir. 2003).  We review the                        
          determination to deny relief under section 6015(f) under an abuse           
          of discretion standard.  See Ewing v. Commissioner, 122 T.C. ___            
          (2004); Washington v. Commissioner, 120 T.C. 137, 146 (2003).               
          Petitioner must show that respondent’s action in denying relief             
          was arbitrary, capricious, or without sound basis in fact.                  
          Jonson v. Commissioner, supra at 125.                                       
               As directed by section 6015(f), the Commissioner has                   
          prescribed procedures to determine whether a taxpayer qualifies             
          for relief from joint and several liability under section                   
          6015(f).  These procedures are set forth in Rev. Proc. 2000-15,             
          2000-1 C.B. 447.  The Court has upheld the use of these                     
          procedures in reviewing a negative determination.  See Washington           
          v. Commissioner, supra at 147; Jonson v. Commissioner, supra at             
          125.                                                                        
               Because of the dearth of evidence in the record on the                 
          conditions and circumstances specified in Rev. Proc. 2000-15,               
          sec. 4.03, 2000-1 C.B. at 448, we need not address all the                  
          factors that are listed there.  It appears that the unpaid                  
          liability was not attributable or attributed by the examiner to             
          petitioner.  Although the decree specified Malone’s obligation to           
          reimburse petitioner with respect to the setoff of her 1999                 




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