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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.
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. At
the time that petitioner requested relief under section 6015(f),
those procedures were found in Rev. Proc. 2000-15, 2000-1 C.B.
447. This Court has upheld the use of these procedures in
reviewing a negative determination. See, e.g., Washington v.
Commissioner, supra at 147-152; Jonson v. Commissioner, supra at
125-126. (Subsequent modification of these procedures by Rev.
Proc. 2003-61, 2003-32 I.R.B. 296, does not affect our analysis
of this case.)
Rev. Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448, lists
seven threshold conditions that must be satisfied before the
Commissioner will consider a request for relief under section
6015(f). Respondent has not argued that petitioner failed to
meet those seven threshold conditions. If the threshold
conditions are satisfied, Rev. Proc. 2000-15, sec. 4.02, 2000-1
C.B. at 448, lists the circumstances, which we refer to as
elements, under which the Commissioner will generally grant
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