- 42 -
Based upon our examination of the entire record before us, we
find that petitioner has failed to carry her burden of establish-
ing that there is an understatement of tax for any of the taxable
years 1989, 1991, 1992, and 1993 that is attributable to erroneous
items of Mr. Monsour. On that record, we further find that
petitioner has failed to satisfy section 6015(b)(1)(B) for any of
those years.37
Conclusion
Based upon our examination of the entire record before us, we
find that petitioner has failed to carry her burden of establish-
ing that she is entitled to relief under section 6015(b) for any
of the taxable years 1989, 1991, 1992, and 1993.
Section 6015(f)
Petitioner claims, in the alternative, that she is entitled
to relief under section 6015(f) for each of the taxable years
1989, 1991, 1992, and 1993. She also claims that she is entitled
to relief under that section for the taxable year 1990. We review
respondent’s denial of relief under section 6015(f) for abuse of
discretion. Butler v. Commissioner, 114 T.C. 276, 292 (2000).
Section 6015(f) provides:
37Assuming arguendo that we had found that petitioner satis-
fied sec. 6015(b)(1)(B), on the record before us, we find for the
reasons set forth below in our consideration of petitioner’s
position with respect to sec. 6015(f) that petitioner has failed
to establish that she satisfies sec. 6015(b)(1)(C) and (D) for
any of the taxable years 1989, 1991, 1992, and 1993.
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