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weighing against granting relief to Ms. Wang. First, she clearly
knew about the employee business expense deductions because Mr.
Applegate gave her his receipts and she used them to prepare
their tax return. Second, Ms. Wang received significant benefit
from Mr. Applegate's employee business expense deductions. His
expenses of $31,349.50 equaled almost 30 percent of their gross
income and constituted almost 70 percent of their total itemized
deductions. Finally, Ms. Wang has provided no information at all
to show that she will experience economic hardship if relief from
the liability is not granted.
Accordingly, the Court concludes that it is not inequitable
under section 6015(f) to hold Ms. Wang liable for the deficiency.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decisions will be entered for
respondent in docket Nos. 19676-02S
and 19692-02S.
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