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weighing against relief.” Rev. Proc. 2000-15, sec. 4.03(2)(b),
2000-1 C.B. at 449. Mr. Sjodin testified that petitioner’s
application for relief under section 6015 was the result of
advice from the family’s accountant as part of his estate
planning. While we recognize that Mr. Sjodin’s disorder has made
communication difficult over the years, it seems that
petitioner’s lack of involvement in the family finances was a
function of the way petitioner and Mr. Sjodin chose to manage
their household duties. Although payment of the liabilities now
will present an economic hardship to petitioner, we cannot say
that under all of the circumstances respondent abused his
discretion by acting arbitrarily, capriciously, or without sound
basis in fact in denying petitioner’s request for equitable
relief under section 6015(f).
Decision will be entered
for respondent.
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