Louise Demirjian - Page 20

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          tax items.  See Hopkins v. Commissioner, 121 T.C. at 77.                    
          Consequently, the understatement of tax on the first amended                
          joint return and the 1992-1994 interest liability that resulted             
          from that understatement are attributable to petitioner.                    
               Based on our examination of the facts and circumstances in             
          this case, many of the factors in Rev. Proc. 2000-15, sec. 4.03,            
          2000-1 C.B. at 448, are neutral.  With respect to the factors               
          that are not neutral, those weighing against granting petitioner            
          relief outweigh those weighing in favor of granting her relief.             
          Accordingly, we conclude that respondent did not abuse his                  
          discretion by acting arbitrarily, capriciously, or without sound            
          basis in fact in denying petitioner’s request for equitable                 
          relief under section 6015(f).                                               
          Conclusion                                                                  
               We hold that respondent did not abuse his discretion in                
          denying petitioner relief from joint and several liability under            
          section 6015.  We have considered the arguments of the parties              
          that were not specifically addressed in this opinion.  Those                
          arguments are either without merit or irrelevant to our decision.           
               To reflect the foregoing,                                              

                                                   Decision will be entered           
                                             for respondent.                          








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