Marianne Hopkins - Page 26

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               3.  Section 6015(f)                                                    
               After we grant relief to petitioner under section 6015(c),             
          she may still have some liability for portions of the                       
          deficiencies for 1982, 1983, and 1984 that are allocable to her             
          under section 6015(d).  We will therefore consider her                      
          eligibility for relief under section 6015(f).  Under section                
          6015(f), the Secretary is authorized to grant equitable relief              
          where:  (1) The taxpayer is not entitled to relief under section            
          6015(b) or (c), and (2) “taking into account all the facts and              
          circumstances, it is inequitable to hold the individual liable              
          for any unpaid tax or any deficiency (or any portion of either)”.           
          See Cheshire v. Commissioner, 282 F.3d at 338.  We review for an            
          abuse of discretion the Commissioner’s decision not to grant                
          equitable relief.  Butler v. Commissioner, 114 T.C. 276, 292                
               The Far West Drilling deductions and the overstated NOL                
          carryforward deductions greatly reduced petitioner and Mr.                  
          Hopkins’s joint tax liabilities in 1982, 1983, and 1984.  In or             
          about those years, considerable amounts were spent to rebuild               
          petitioner’s house at 111 Diablo Drive.  Petitioner was, and                
          still is, the sole owner of that residence, and she was the                 
          person who received the most comfort and benefit from the use of            
          that residence before and after those years.  The reduced tax               
          liabilities for 1982, 1983, and 1984 enhanced petitioner’s                  

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