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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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Last modified: May 25, 2011