John A. and Donna L. Rowe - Page 13




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          parties’ arguments on brief did not address these settled issues,           
          which leads us to the conclusion that those issues were settled             
          well before the actual filing of the stipulation.  Accordingly,             
          petitioner has failed to establish that respondent’s position               
          with respect to these conceded issues was not substantially                 
          justified.  See, e.g., Lozon v. Commissioner, T.C. Memo. 1997-              
          537.                                                                        
               C.   Respondent’s Denial of Relief Under Section 6015                  
               Petitioner made valid elections for relief from joint and              
          several liability under section 6015(b), (c), and (f).  Before              
          and after trial, respondent conceded that petitioner was entitled           
          to partial relief under section 6015.  We have already held that            
          respondent’s position with respect to these concessions was                 
          substantially justified.  Respondent denied petitioner relief               
          under section 6015(b), (c), and (f) with respect to the remaining           
          deficiencies, additions to tax, and penalties.  In Rowe I, we               
          relied on section 6015(c) and (f) and held that petitioner was              
          entitled to relief from joint and several liability for the                 
          remaining portions of the disputed deficiencies, additions to               
          tax, and penalties.  Petitioner argues that respondent was not              
          substantially justified in denying her relief under section                 
          6015(b), (c), and (f) with respect to the issues we decided in              
          her favor.                                                                  








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