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we find that the factors against equitable relief outweigh the
factors in favor of equitable relief. Accordingly, we hold that
it was not an abuse of discretion by respondent to deny
petitioner’s claim for equitable relief under section 6015(f).
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011