Kathleen E. Gilliam - Page 12

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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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