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Because the 1995 tax liability was paid in full, no relief
is available to petitioner under section 6015(c). Petitioner
admits to knowing about the pension income, unemployment
compensation, and State income tax refund and is therefore not
eligible for relief from joint liability under section 6015(b)
with respect to those items of unreported income.
As to the $472 in barter income, respondent argues that
petitioner does not qualify for relief under section 6015(b)
because petitioner’s knowledge of intervenor’s relationship with
Itex gave petitioner reason to know of the income earned by
intervenor from the bartering activity. We agree.
Although some factors arguably support petitioner’s claim to
equitable relief under section 6015(f) as to the total $1,808
petitioner paid, the evidence does not establish that respondent
abused his discretion in denying such relief. We note
particularly petitioner’s actual knowledge of three of the four
items of unreported income, and we note petitioner’s various tax
protester arguments made herein.
Petitioner is not entitled to relief from any portion of the
tax, interest, and penalties she paid with respect to her 1995
joint Federal income tax liability.
Decision will be entered for
respondent.
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Last modified: May 25, 2011