- 9 -
will be considered and weighed appropriately.” Rev. Proc. 2000-
15, sec. 4.03, 2000-1 C.B. at 448.
Finally, we would be hard pressed to find that petitioner
derived a significant benefit from the items that gave rise to
the deficiency. The loss from the Schedule C was used to offset
the former husband’s income and not petitioner’s income.
In sum, we find that all factors considered support the
conclusion that petitioner is entitled to relief under section
6015(f) and that respondent’s denial of relief was an abuse of
discretion.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for petitioner.
Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011