- 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