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that in 1991 she purchased real estate in Ocean City for
$130,000, that the current value of that real estate was
$500,000, and that there was a $450,000 outstanding mortgage loan
with respect to that real estate, which was required to be paid
in full in 2035.
In section 7 of petitioner’s Form 433-A, petitioner indi-
cated that she had personal assets valued at $6,000.
Section 9 of Form 433-A listed various income items and
various living expense items. With respect to the income items
listed in that section, petitioner stated that she was unem-
ployed. With respect to the expense items listed in section 9 of
Form 433-A, petitioner indicated that she had total monthly
living expenses of $4,003, consisting of $3,600 of monthly
expenses for housing and utilities and $403 of monthly expenses
for food, clothing, housekeeping supplies, and personal care
products.
OPINION
We review respondent’s denial of relief under section
6015(f) for abuse of discretion. Butler v. Commissioner, 114
T.C. 276, 292 (2000). Respondent’s denial of such relief consti-
tutes an abuse of discretion if such denial was arbitrary,
capricious, or without sound basis in fact or law. Woodral v.
Commissioner, 112 T.C. 19, 23 (1999). The question whether
respondent’s denial of relief under section 6015(f) was arbi-
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