Michael B. Butler and Jean Butler - Page 27




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          engaged in the family's finances.  Moreover, the record does not            
          demonstrate that there would be any economic hardship to                    
          petitioner if relief were not granted.  Petitioner remains                  
          married to her husband and is living with him in the same                   
          household.  Additionally, there is no evidence that petitioner's            
          husband has ever abused petitioner in any manner.  Petitioner's             
          husband has always applied all of his income toward the benefit             
          of his family.  At her meeting with the IRS Appeals Officer,                
          petitioner did not come forward with any additional evidence that           
          would support her claim for equitable relief.  In short, there              
          were no compelling reasons in the instant case for respondent to            
          grant petitioner equitable relief.  Consequently, we hold that it           
          was not an abuse of discretion for respondent to deny                       
          petitioner's claim for equitable relief pursuant to section                 
          6015(f).                                                                    
               To reflect the foregoing,                                              
                                                  An appropriate order will           
                                             be issued and decision will be           
                                             entered for respondent.                  















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