- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011