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disallowed itemized deductions is allocable to Ms. Moore and what
is allocable to him. Accordingly, petitioner is not entitled to
relief under section 6015(c) with respect to the portion of
deficiency attributable to these items.
3. Section 6015(f)
Since petitioner is not entitled to relief under section
6015(b) or (c), with respect to the unreported unemployment
compensation and the disallowed itemized deductions, we consider
whether petitioner qualifies for relief under section 6015(f),
after a trial de novo and using an abuse of discretion standard.
See Ewing v. Commissioner, 122 T.C. 32 (2004); Fernandez v.
Commissioner, 114 T.C. at 328-329; Butler v. Commissioner, 114
T.C. at 287-292. Petitioner bears the burden of proving that
respondent’s denial of equitable relief under section 6015(f) was
an abuse of discretion. See Rule 142(a); Alt v. Commissioner,
supra at 311. Petitioner must demonstrate that respondent
exercised his discretion arbitrarily, capriciously, or without
sound basis in fact or law. See Jonson v. Commissioner, 118 T.C.
106, 125 (2002), affd. 353 F.3d 1181 (10th Cir. 2003); Woodral v.
Commissioner, 112 T.C. 19, 23 (1999).
As previously discussed, the Commissioner has prescribed
procedures for determining whether a spouse qualifies for relief
under subsection (f). We have upheld the procedures found in
Rev. Proc. 2000-15, 2000-1 C.B. 447, in reviewing a
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