- 9 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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