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4.03(2)(b), that knowledge that the tax would not be paid is an
“extremely strong factor”, the Court finds, considering all the
facts and circumstances, that respondent did not abuse his
discretion in denying petitioner equitable relief from joint and
severable liability under section 6015(f).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decisions will be entered
for respondent.
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Last modified: May 25, 2011