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Parker’s pension distributions. As stated above, we find that
petitioner had knowledge of Mrs. Parker’s pension distributions.
Petitioner also received a significant benefit from Mrs. Parker’s
pension distributions. Shortly after the pension distributions
were deposited in the joint money market account, petitioner
withdrew almost all of the money market account funds. Although
petitioner was required to return some of the withdrawn funds, he
ultimately received a portion of the funds in the divorce
settlement. Additionally, since the taxable year 1997,
petitioner has not complied with all Federal tax laws.
Petitioner testified that he had never reported any sales or
income from the small business he has continued to maintain.
Petitioner also failed to establish economic hardship.
Despite petitioner’s claim of monthly income limited to $704 from
SSA, petitioner continued to maintain his small business of
selling antiques and collectibles. At trial, respondent provided
evidence that from September of 1998 through November of 2001,
petitioner purchased over 190 items totaling more than $22,000
from just one Internet bidding service. Petitioner claims he did
not receive some of the items. Even if we reduce the amount by
25 percent, $16,500 is a substantial expense.
Under the facts and circumstances presented in this case, we
hold that respondent did not abuse his discretion in denying
equitable relief to petitioner under section 6015(f) with respect
to the unreported income items or the section 6662(a) accuracy-
related penalty.
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