- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011