- 11 - addition, and as discussed above, petitioner had knowledge (actual or constructive) of the understatement of tax on the return. Accordingly, we conclude that respondent did not abuse his discretion in denying relief under section 6015(f). Conclusion We hold that petitioner is not entitled to relief under section 6015(b) or (c) and that respondent did not abuse his discretion in denying relief from joint and several liability under section 6015(f). We sustain respondent’s determination of a deficiency in this case. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011