- 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.
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