- 21 - the corporation was not reimbursed for personal use of the yacht. To the extent of these items, therefore, respondent has proven that petitioner had actual knowledge disqualifying her from relief under section 6015(c). Aside from her overall denials and disclaimers, petitioner has given us no reason to reject respondent’s allocations of amounts for which petitioner is not entitled to relief under section 6015(c). Except as set forth above with respect to transfers before September 5, 1989, she is not entitled to relief beyond the concessions made by respondent in the posttrial brief. Section 6015(f) Analysis Section 6015(f) provides an additional opportunity for relief to those taxpayers who do not otherwise meet the requirements of subsection (b) or (c) of section 6015. Specifically, section 6015(f) gives respondent the discretion to grant equitable relief from joint and several liability if “taking into account all the facts and circumstances, it is inequitable to hold the individual liable for any unpaid tax”. We have jurisdiction to review respondent’s denial of petitioner’s request for equitable relief under section 6015(f). Jonson v. Commissioner, 118 T.C. 106, 125 (2002), affd. 353 F.3d 1181 (10th Cir. 2003); Butler v. Commissioner, 114 T.C. at 292. We review such denial of relief to decide whether respondent abused his discretion by acting arbitrarily, capriciously, or without sound basis in fact. Jonson v. Commissioner, supra atPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011