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II. Section 6015(f)
We note this case involves an unpaid tax liability for the
year in issue. Because this case does not involve a deficiency
or understatement, petitioner does not qualify for relief under
section 6015(b) or (c). See sec. 6015(b)(1) and (c)(1);
Washington v. Commissioner, 120 T.C. 137, 146-147 (2003).
Therefore, our review is limited to section 6015(f), which
permits in certain circumstances relief from joint and several
liability for unpaid taxes. See Ewing v. Commissioner, 118 T.C.
494, 497 (2002). Section 6015(f) grants the Commissioner
discretion to grant equitable relief from tax liability to a
spouse if, taking into account all the facts and circumstances,
it is inequitable to hold the spouse liable for any unpaid tax or
any deficiency (or any portion of either), and relief is not
available under section 6015(b) or (c). In order to prevail, the
taxpayer must demonstrate that the Commissioner abused his
discretion by acting arbitrarily, capriciously, clearly
unlawfully, or without sound basis in fact or law. See Jonson v.
Commissioner, 118 T.C. 106, 125 (2002), affd. 353 F.3d 1181 (10th
Cir. 2003); Butler v. Commissioner, 114 T.C. 276, 289-290 (2000).
Here, petitioner bears the burden of proving that respondent
abused his discretion in denying her equitable relief under
section 6015(f). See Rule 142(a); Alt v. Commissioner, 119 T.C.
306, 311 (2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004);
Ogonoski v. Commissioner, T.C. Memo. 2004-52. We have
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