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based on the conclusions of two revenue agents, Ann Hoel and Al
Petroff (Mr. Petroff).
In analyzing petitioner’s entitlement to equitable relief
under section 6015(f), the revenue agents determined: (1)
Petitioner was divorced at the time she requested relief; (2)
petitioner would suffer economic hardship if relief was not
granted; (3) petitioner did not significantly benefit from the
unpaid tax liabilities; (4) petitioner had made a good faith
effort to comply with the Federal income tax laws in the tax
years following the years at issue; and (5) there were no
perceptible asset transfers between petitioner and Mr. Foor. The
agents determined that petitioner knew or had reason to know that
the tax liabilities would not be paid and that the liabilities
were not solely attributable to Mr. Foor. The revenue agents
noted that petitioner was responsible for at least a portion of
the underpayments because of inadequate withholding.
Petitioner filed a petition under section 6015(e)(1) seeking
review of respondent’s determinations for the taxable years 1983,
1984, 1985, 1987, 1990, and 1991. The petition lists section
6015(b), (c), and (f) and alleges that it would be inequitable to
hold petitioner responsible for the unpaid taxes.
OPINION
This case involves unpaid taxes for the years in issue.
Because no understatements of tax or deficiencies are involved,
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