- 41 - participated in making those investments. This factor weighs against granting petitioner equitable relief under section 6015(f). b. Knowledge or Reason to Know For the reasons stated in our analysis of the corresponding positive factor, we conclude that petitioner had reason to know of the items giving rise to the deficiencies in this case and/or failed to satisfy her duty of inquiry regarding the items. This factor weighs heavily against granting petitioner equitable relief under section 6015(f). Rev. Proc. 2000-15, sec. 4.03(2)(b). c. Significant Benefit Petitioner argues she did not significantly benefit beyond normal support from the Hoyt partnership losses and investment tax credits giving rise to the deficiencies. Yet, because of the investment, petitioner and Mr. Abelein received tax savings of $18,806 they otherwise would not have received. In Doyle v. Commissioner, T.C. Memo. 2003-96, affd. 94 Fed. Appx. 949 (3d Cir. 2004), we held that a requesting spouse significantly benefited from the items giving rise to the deficiency, which were tax shelter deductions, because she received significant tax refunds as a result of the items. Likewise, in this case, petitioner and Mr. Abelein received substantial income tax refunds as a result of the items giving rise to the deficiencies.Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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