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of equitable relief under section 6015(f) was an abuse of
discretion. Rule 142(a); Alt v. Commissioner, 119 T.C. 306, 311
(2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004); Jonson v.
Commissioner, 118 T.C. 106, 113 (2002), affd. 353 F.3d 1181 (10th
Cir. 2003). Petitioner must demonstrate that respondent
exercised his discretion arbitrarily, capriciously, or without
sound basis in fact or law. Jonson v. Commissioner, supra at
125; Woodral v. Commissioner, 112 T.C. 19, 23 (1999).
Section 6015(f) provides:
SEC. 6015(f). Equitable Relief.--Under procedures
prescribed by the Secretary, if--
(1) taking into account all the facts
and circumstances, it is nequitable to hold
the individual liable for any unpaid tax or
any deficiency (or any portion of either);
and
(2) relief is not available to such
individual under subsection (b) or (c),
the Secretary may relieve such individual of such
liability.
As directed by section 6015(f), the Commissioner has
prescribed procedures to be used in determining whether the
requesting spouse qualifies for relief from joint and several
liability under section 6015(f). As applicable to the present
case, these procedures are set forth in Rev. Proc. 2000-15, 2000-
1 C.B. 447.4 The requesting spouse must satisfy seven conditions
4 Rev. Proc. 2003-61, 2003-2 C.B. 296, which supersedes
(continued...)
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