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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.
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Last modified: May 25, 2011