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neither respondent nor intervenor assert that intervenor lacks
the ability to fulfill her legal obligation.
Contrary to respondent’s determination, we find that the
above factors favoring equitable relief clearly outweigh the fact
that petitioner had actual knowledge of the unreported income.
Under the circumstances of this case, we find that it was an
abuse of discretion for respondent to deny petitioner relief from
liability for the deficiency and penalty pursuant to section
6015(f).
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for petitioner.
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Last modified: May 25, 2011