- 18 -
fact or law. See id.; Woodral v. Commissioner, 112 T.C. 19, 23
(1999).
The Commissioner has prescribed procedures as directed by
section 6015(f) for determining whether a spouse qualifies for
relief under subsection (f). These procedures are set forth in
Rev. Proc. 2003-61, 2003-2 C.B. 296. Rev. Proc. 2003-61, supra,
which applies here, has a nonexhaustive list of factors weighing
in favor of relief and factors weighing against relief. Stanley
has failed to present any evidence that would suggest with regard
to these factors that Tomi did not qualify for equitable relief
as respondent determined. Accordingly, we conclude that
respondent did not abuse his discretion by acting arbitrarily,
capriciously, or without sound basis in fact in granting Tomi
equitable relief under section 6015(f).
We have considered all arguments the parties made in
reaching our holdings, and, to the extent not mentioned, we find
them to be irrelevant or without merit.
To reflect the foregoing,
An appropriate decision will
be entered.
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