- 13 - 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011