- 23 -
Commissioner, 115 T.C. 183, 198 (2000), affd. 282 F.3d 326 (5th
Cir. 2002).
Respondent denied petitioner’s request for equitable relief
under section 6015(f) for 1991 through 1999 on the basis that she
had failed to reply to respondent’s request for additional
information.12 We note that in reviewing whether respondent’s
determination was an abuse of discretion, our finding is made in
a trial de novo and is not limited to matter contained in
respondent’s administrative record. Ewing v. Commissioner, 122
T.C. 32, 44 (2004).
As directed by section 6015(f), the Commissioner has
prescribed guidelines in Rev. Proc. 2000-15, 2000-1 C.B. 447,
448, that the Commissioner will consider in determining whether
an individual qualifies for relief under section 6015(f). Rev.
Proc. 2000-15, sec. 4.01, 2000-1 C.B. at 448, lists seven
conditions (threshold conditions) which must be satisfied before
the Commissioner will consider a request for relief under section
6015(f). Respondent agrees that those threshold conditions are
satisfied in this case.13
12 Petitioner alleges that her failure to respond and
provide additional information resulted from the letters to her
from the Internal Revenue Service not being forwarded timely to
her by Levy and other persons at her accountant’s old business
office address.
13 Rev. Proc. 2003-61, 2003-2 C.B. 296, 299, which
superseded Rev. Proc. 2000-15, 2000-1 C.B. 447, is not applicable
(continued...)
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