Angela Rae Zachry, Petitioner, and Curtis Carlin, Intervenor - Page 12

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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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