- 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 Proc. 2003-61, 2003-2 C.B. 296, 299, which superseded Rev.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...)Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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