- 9 - arguments, issues, and other matters that were raised at the administrative hearing or otherwise brought to the attention of the Office of Appeals. Magana v. Commissioner, 118 T.C. 488, 493-494 (2002); sec. 301.6320-1(f)(2), Q&A-F5, Proced. & Admin. Regs. As stated supra note 5, petitioner raised at the administrative hearing the same issues and arguments supported by the exhibits submitted after trial. We do not further address respondent’s argument that our review is limited to the administrative record. A. Eligibility for Equitable Relief As directed by section 6015(f), the Commissioner has prescribed guidelines for determining whether a spouse qualifies for relief under subsection (f). The applicable provisions are found in Rev. Proc. 2003-61, 2003-2 C.B. 296, modifying Rev. Proc. 2000-15, 2000-1 C.B. 447. The requesting spouse must satisfy seven conditions (threshold conditions) before the Commissioner will consider a request for relief under section 6015(f). Rev. Proc. 2003-61, sec. 4.01, 2003-2 C.B. at 297. The 5(...continued) issue of relief under sec. 6015 at the administrative hearing, and more specifically, she discussed the police reports with regard to her sec. 6015 claim for relief with the Appeals officer and informed him of the reasons she did not pay the tax liabilities for the years in issue. See Magana v. Commissioner, 118 T.C. 488, 493-494 (2002). On the basis of the issues petitioner raised in her administrative hearing, respondent’s objections are overruled, and we consider the additional exhibits in our review of respondent’s determination.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: November 10, 2007