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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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