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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.
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