Fredie Lynn Charlton - Page 11




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          section 6015(b), a taxpayer must show that it is inequitable to             
          be held liable for tax due on a joint return.  See sec.                     
          6015(b)(1)(D).  Under section 6015(f), the Secretary may grant              
          relief from joint liability if it is inequitable to hold the                
          individual liable for any unpaid tax or deficiency.  Charlton was           
          present at trial.  Thus, he had the opportunity to present                  
          evidence relating to whether or to what extent it was equitable             
          to hold Hawthorne jointly liable for tax.  He did not establish             
          that it was an abuse of discretion for respondent to relieve                
          Hawthorne from joint liability to the extent determined by                  
          respondent under section 6015(f).                                           
          Based on the Form 886A and the trial record in these cases,                 
          we conclude that respondent’s grant of relief to Hawthorne under            
          section 6015(f) was not an abuse of discretion.  Thus, we sustain           
          that determination.                                                         
               For the foregoing reasons,                                             


                                                  Decision will be                    
                                             entered consistent with agreed           
                                             computations submitted under             
                                             Rule 155 by respondent and               
                                             Hawthorne in docket No.                  
                                             11861-98 and consistent with             









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