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factors. Although we do not find fault with the determination
that petitioner had reason to know that the reported tax
liabilities would not be paid, on the basis of the particular
facts and circumstances involved, we find that compelling reasons
existed to grant equitable relief. Petitioner is divorced, she
will suffer economic hardship if relief is not granted, she did
not significantly benefit from the unpaid taxes, and there were
several other factors known to respondent at the time of the
determination that weighed in favor of granting relief.
Consequently, we hold that respondent’s denial of equitable
relief was an abuse of discretion and that it would be
inequitable to hold petitioner liable for the unpaid tax
liabilities for the years in issue.
Decision will be entered
for petitioner.
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