Marie-Francine T. Grow - Page 10

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          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.                          























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