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call into doubt respondent’s determination that she could not
have reasonably believed that Mr. Rooks would pay the relevant
tax liabilities at the time she signed these returns. Nor is
there any indication that petitioner would suffer economic
hardship if relief is not granted. Based on the record before
this Court, we do not find respondent’s denial of section 6015
relief to be arbitrary, capricious, or without sound basis in
fact or law.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011