Renee Trupin D'Aunay - Page 23

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          Id.  A requesting spouse must satisfy all seven threshold                   
          conditions before respondent will consider his or her request for           
          equitable relief under section 6015(f).  Id.  We have upheld the            
          use of these procedures in reviewing a negative determination.              
          See Washington v. Commissioner, supra at 147; Jonson v.                     
          Commissioner, supra at 125.                                                 
               As indicated above with reference to section 6015(b),                  
          considering the facts and circumstances in this case, we cannot             
          conclude that it would be inequitable to hold petitioner liable             
          for the deficiencies resulting from her filing joint returns with           
          Trupin for the years in issue.  A fortiori, we cannot conclude              
          that denial of relief was an abuse of discretion, i.e.,                     
          arbitrary, capricious, or without sound basis in fact.  See Ewing           
          v. Commissioner, 122 T.C. 32, 39 (2004).                                    
               Petitioner’s predicament has resulted from the activities in           
          which she engaged with her former husband, Trupin, exacerbated by           
          her activities with her husband, D’Aunay.                                   
               (It may occur to the reader that petitioner could or should            
          make an offer in compromise under section 7122.  Her refusal to             
          provide financial information to the IRS, however, also precludes           
          that avenue of relief.)                                                     
               To take account of respondent’s concessions of the extent to           
          which petitioner may be relieved from liability under section               
          6015(c),                                                                    







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