Rosalinda E. Alt - Page 19




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          supra at 291.  Further, the equitable factors we considered under             
          section 6015(b)(1)(D) are the same equitable factors we consider              
          under section 6015(f).13  As a result, we hold that respondent                
          did not abuse his discretion in denying petitioner relief under               
          section 6015(f) for taxable years 1982 to 1988.                               
               In reaching our holdings, we have considered all arguments               
          made by the parties, and, to the extent not mentioned above, we               
          conclude they are irrelevant or without merit.                                
               To reflect the foregoing,                                                
                                                   Decision will be entered             
                                              for respondent.                           












               12(...continued)                                                         
          roots in the equity test of former subparagraph 6013(e)(1)(D)                 
          carried forward into subparagraph 6015(b)(1)(D).”), affg. T.C.                
          Memo. 2000-332.                                                               
               13 The Commissioner has announced a list of factors in Rev.              
          Proc. 2000-15, sec. 4.03, 2000-1 C.B. 447, 448, that the                      
          Commissioner will consider in deciding whether to grant equitable             
          relief under sec. 6015(f).  The revenue procedure takes into                  
          account factors such as marital status, economic hardship, and                
          significant benefit in determining whether relief will be granted             
          under sec. 6015(f).  Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B.               
          at 448.                                                                       





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