Timothy R. Becherer - Page 9

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               Petitioner knew of Ms. Becherer’s employment with TTC                  
          Illinois, Trader Publications, and Pennysaver.  The three items             
          of her income from such employment were omitted from the 1996               
          return.  Petitioner aided Ms. Becherer in performing her                    
          employment duties for Trader Publications and Pennysaver.                   
          Petitioner also knew of Ms. Becherer’s employment with TTC                  
          Illinois.  Petitioner therefore had an actual and clear awareness           
          of the existence of the items that gave rise to the deficiency.             
          Consequently, relief under section 6015(c) is unavailable to                
          petitioner.                                                                 
          III. Relief Under Section 6015(f)                                           
               Respondent argues that he did not abuse his discretion in              
          denying petitioner equitable relief under section 6015(f).                  
          Respondent’s denial of relief is reviewed under an abuse of                 
          discretion standard.  Cheshire v. Commissioner, 115 T.C. at 198;            
          Butler v. Commissioner, 114 T.C. at 292.                                    
               Considering the facts and circumstances of this case, we               
          held under section 6015(b)(1)(D) that it is not inequitable to              
          hold petitioner liable for the deficiencies.  The language of               
          section 6015(f)(1), “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)”            
          does not differ significantly from the language of section                  
          6015(b)(1)(D), “taking into account all the facts and                       






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