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Taking into account all the facts and circumstances, we
conclude that petitioner has satisfied each element under section
4.02(1) of the revenue procedure and it would be inequitable to
hold her liable for the unpaid taxes. On the basis of the record
before us, we hold that respondent abused his discretion in
denying petitioner’s claim for relief under section 6015(f).
In reaching our holding, we have considered all arguments
made by the parties, and, to the extent not mentioned above, we
find them to be irrelevant or without merit.
To reflect the foregoing,
Decision will be
entered for petitioner.
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Last modified: May 25, 2011