Tracie Young - Page 15

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          all relevant factors, regardless of whether the factor is listed            
          in Rev. Proc. 2000-15, sec. 4.03, will be considered and weighed.           
               To prevail under section 6015(f), petitioner must show that            
          respondent’s denial of equitable relief from joint liability                
          under section 6015(f) was an abuse of discretion.  See Washington           
          v. Commissioner, 120 T.C. at 146; Jonson v. Commissioner, 118               
          T.C. 106, 125 (2002) (citing Butler v. Commissioner, 114 T.C. at            
          292), affd. 353 F.3d 1181 (10th Cir. 2003).  Action constitutes             
          an abuse of discretion under this standard where it is arbitrary,           
          capricious, or without sound basis in fact or law.  Woodral v.              
          Commissioner, 112 T.C. 19, 23 (1999).  The question of whether              
          respondent’s determination was arbitrary, capricious, or without            
          sound basis in fact is a question of fact.  Cheshire v.                     
          Commissioner, 115 T.C. at 198.  In deciding whether respondent’s            
          determination that petitioner is not entitled to relief under               
          section 6015(f) was an abuse of discretion, we consider evidence            
          relating to all the facts and circumstances.                                
               Respondent contends:  (1) Petitioner voluntarily signed the            
          1995 joint Federal income tax return which reported gross income            
          of $27,382; (2) the proceeds of Mr. Glaze’s wage income from                
          Mayflower were put into a joint checking account to which                   
          petitioner had access; (3) petitioner obtained benefits due to              
          Mr. Glaze’s wage income received from Mayflower through the use             
          of those moneys to pay off household expenses; (4) petitioner               

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