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circumstances, petitioner does not present the unusually strong
case in favor of equitable relief despite her knowledge that the
liability would be unpaid, as contemplated by Rev. Proc. 2000-15,
sec. 4.03(2)(b), 2000-1 C.B. at 449. The Court holds that
respondent committed no abuse of discretion in denying section
6015(f) relief to petitioner for the year 1987.6
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
5(...continued)
Commissioner or the Commissioner’s delegate and will be based on
rules similar to those provided in sec. 301.6343-1(b)(4), Proced.
& Admin. Regs. Such regulation provides that the Commissioner
will consider any information provided by the taxpayer that is
relevant to the determination, including, but not limited to, the
taxpayer’s age, ability to earn, responsibility for dependents,
and the amount reasonably necessary for basic living expenses.
Petitioner presented insufficient evidence to support a finding
of economic hardship. She did not provide documentation of her
expenses; she has been employed, and Mr. Barber was providing
child support payments.
6 The Court makes no findings regarding the applicability
of the factors listed in Rev. Proc. 2000-15, supra, to any other
year.
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