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for the taxpayer to be held liable for a portion of the
understatement. As previously discussed, other than the blanket
statement that “it would be inequitable” to make her pay,
petitioner submitted no evidence to the Appeals officer to
support her claim for relief under section 6015(f).
Petitioner bears a heavy burden of proof and respondent’s
position deserves the Court’s deference. This Court does not
interfere unless respondent’s determination is arbitrary,
capricious, clearly unlawful, or without sound basis in fact or
law. Ewing v. Commissioner, 122 T.C. 32, 39 (2004). Petitioner
presented no additional evidence at trial to support her claim
for relief under section 6015(f); therefore, the Court finds
there was no abuse of discretion by the Appeals officer in
denying her claim for equitable relief under section 6015(f).
Petitioner received an appropriate hearing for purposes of
section 6330(b)(1). Day v. Commissioner, T.C. Memo. 2004-30;
Leineweber v. Commissioner, T.C. Memo. 2004-17; sec. 301.6330-
1(d)(2), Q&A-D6, Proced. & Admin. Regs. Respondent properly
verified that the requirements of applicable law and
administrative procedures were met and balanced the need for
efficient collection of taxes with the legitimate concern of
petitioner that the collection action be no more intrusive than
necessary. On this record, the Court holds that there was no
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Last modified: May 25, 2011