- 22 - v. Commissioner, 20 F.3d 1128, 1136-1137 (11th Cir. 1994), affg. T.C. Memo. 1993-17. In addition, respondent has not shown that petitioner had actual knowledge of the item giving rise to the deficiency. See sec. 6015(c)(3)(C). Accordingly, we hold that petitioner is entitled to relief under section 6015(c) from joint liability for the 1979 deficiency. In light of this holding, we need not consider whether petitioner is eligible to receive relief under section 6015(f) for 1979.11 C. Relief Under Section 6015(f) for 1991 Through 1999 Respondent denied petitioner’s request for equitable relief under section 6015(f) from joint liability for 1991, 1992, 1993, 1994, 1995, 1996, 1997, 1998, and 1999. We have jurisdiction to review the Commissioner’s denial of a requesting spouse’s request for equitable relief under section 6015(f). Washington v. Commissioner, 120 T.C. at 145; Ewing v. Commissioner, 118 T.C. 494, 497-507 (2002). To prevail, petitioner must establish that respondent’s denial of equitable relief under section 6015(f) was an abuse of discretion. Washington v. Commissioner, supra at 146; Cheshire v. 11 Refunds are limited to situations where relief is granted under sec. 6015(b) or (f). See sec. 6015(g). However, there is no indication in the record that petitioner would be entitled to a refund or credit if granted relief under sec. 6015. Because relief under sec. 6015(f) would not provide petitioner any more relief than she would obtain under sec. 6015(c), we need not give this matter further consideration. See sec. 6015(f)(2).Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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