-11-
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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