Sandra Browda, Petitioner, and David Browda, Intervenor - Page 13

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          suggests that the taxes due for the taxable years in issue were             
          not paid because of an unexpected downturn in intervenor’s                  
          business that persisted over an extended period.  Accordingly, on           
          the record before us, we conclude that petitioner did not have              
          reason to know that the income taxes for the taxable years in               
          issue would not be paid by intervenor.                                      
               B.  Conclusion                                                         

               Based on our review of all the facts and circumstances, we             
          hold that petitioner is entitled to relief under section 6015(f)            
          and that respondent’s denial of relief was an abuse of                      
          discretion.                                                                 

               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   

               To reflect the foregoing,                                              
                                                  Decision will be entered            

                                             for petitioner.                          

















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