- 61 - gains, mortgage interest, and charitable contributions items allocable to petitioner. VIII. Additions to Tax and Penalties Respondent did not determine that the fraud additions to tax pursuant to section 6653(b) for the taxable years 1987 and 1988, and the fraud penalty pursuant to section 6663 for the taxable year 1989, were applicable to petitioner. On brief, respondent concedes that to the extent any relief is granted for a portion of the deficiencies, relief is automatic for the penalties related to that portion. Petitioner concedes that the estimated tax penalty pursuant to section 6654 for 1990 should be allocated proportionally to the allocation of the underlying deficiency. Petitioner contends that it is inequitable to hold her liable for any remaining additions to tax or penalties. We have previously held that we have jurisdiction to review the denial of relief from joint liability under section 6015(f) for additions to tax and penalties. Cheshire v. Commissioner, 115 T.C. at 197-199. We review respondent’s refusal to grant equitable relief for additions to tax or penalties under an abuse of discretion standard. Id. at 198. In Cheshire v. Commissioner, supra, we provided the following guidance in determining whether respondent has abused his discretion in denying equitable relief in situations involving additions to tax or penalties:Page: Previous 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 Next
Last modified: May 25, 2011