Estate of Keith L. Gurr - Page 21




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          amount greater than that conceded by respondent.                            
               Petitioner's final claim for relief is under section                   
          6015(f).  That provision allows the Secretary to relieve a spouse           
          of liability if, taking into account all the facts and                      
          circumstances, it is inequitable to hold the spouse liable for              
          any unpaid tax or deficiency and relief is otherwise not                    
          available under section 6015(b) or (c).  Cheshire v.                        
          Commissioner, 115 T.C. 183, 198 (2000).  This Court's review                
          under section 6015(f) is limited to whether there was an abuse of           
          discretion by the Secretary in denying relief.  Cheshire v.                 
          Commissioner, supra at 198; Butler v. Commissioner, 114 T.C. 276,           
          292 (2000).  On the basis of all the facts and circumstances                
          discussed earlier, petitioner has not established that there was            
          an abuse of discretion by respondent in denying her claim for               
          relief under section 6015(f).                                               
               Reviewed and adopted as the report of the Small Tax                    
          Division.                                                                   


          Decision will be entered                                                    
          under Rule 155.7                                                            

               7    For the year 1993, respondent determined that, because            
          of the income and expense adjustments, $3,936 of Social Security            
          benefits received by petitioner and Mr. Gurr is includable in               
          their gross income.  It appears to the Court that both Mr. Gurr             
          and petitioner received Social Security benefits during 1993;               
                                                             (continued...)           





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