Tracie Young - Page 13

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          basis for the unreported income, and she cannot rely on ignorance           
          of the law for relief from liability.  Mitchell v. Commissioner,            
          292 F.3d 800, 805 (D.C. Cir. 2002), affg. T.C. Memo. 2000-332.              
               C.  Section 6015(f)                                                    
               Therefore, the only remaining opportunity for relief                   
          available to petitioner is section 6015(f).  Section 6015(f)                
          provides as follows:                                                        
                    SEC. 6015(f).  Equitable Relief.--Under procedures                
               prescribed by the Secretary, if-–                                      
                         (1) taking into account all the facts and                    
                    circumstances, it is inequitable to hold the                      
                    individual liable for any unpaid tax or any                       
                    deficiency (or any portion of either); and                        
                         (2) relief is not available to such individual               
                    under subsection (b) or (c),                                      
               the Secretary may relieve such individual of such liability.           
               As directed by section 6015(f), the Commissioner has                   
          prescribed guidelines in Rev. Proc. 2000-15, 2000-1 C.B. 447,3 to           
          be considered 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 threshold conditions which must be                


          3This revenue procedure was superseded by Rev. Proc. 2003-                  
          61, 2003-2 C.B. 296.  Rev. Proc. 2003-61, 2003-2 C.B. 296, is               
          effective either for requests for relief filed on or after Nov.             
          1, 2003, or for requests for which no preliminary determination             
          letter was issued as of Nov. 1, 2003.  In the present case, the             
          request for relief was filed on June 3, 2002, and the preliminary           
          determination letter was issued on Feb. 25, 2003; therefore, Rev.           
          Proc. 2000-15, 2000-1 C.B. 447 is applicable in the present                 
          situation.                                                                  





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