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parents’ expenses. Petitioner and her husband took two trips to
Europe at a cost of approximately $20,000. Petitioner and her
husband transferred real property to their son for $1.
Considering the above, there can be no question that petitioner
materially participated in this plan to make herself and her
husband “collection proof”. It is elementary, of course, that
one seeking equity must do equity. Given the facts of this case,
it is not inequitable to deny petitioner relief from joint income
tax liability.
Equitable Relief-–Section 6015(f)
Alternatively, petitioner asks us to hold that respondent
abused his discretion in denying her equitable relief pursuant to
section 6015(f). See Cheshire v. Commissioner, 115 T.C. 183, 198
(2000), affd. 282 F.3d 326 (5th Cir. 2002); Butler v.
Commissioner, 114 T.C. 276, 292 (2000). Since section 6015(f) is
similar to section 6015(b)(1)(D) and the equitable factors
considered are the same, we hold that respondent did not abuse
his discretion by denying petitioner’s request for relief under
section 6015(f). See Alt v. Commissioner, 119 T.C. at 316;
Barranco v. Commissioner, T.C. Memo. 2003-18.
Conclusion
Respondent did not err in denying petitioner relief from
joint and several income tax liability under section 6015(b) or
(f). We hold that respondent correctly determined that
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