John William Hollis - Page 13

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               3.   Other Facts and Circumstances                                     
               Section 6015(f) provides, inter alia, that, taking into                
          account all of the facts and circumstances, the Commissioner may            
          relieve an individual of joint liability for tax.  Rev. Proc.               
          2000-15, sec. 4.03, states:                                                 
               No single factor will be determinative of whether                      
               equitable relief will or will not be granted in any                    
               particular case.  Rather, all factors will be                          
               considered and weighed appropriately.  The list is not                 
               intended to be exhaustive.                                             
               No matter who made the error on their return (petitioner or            
          intervenor), respondent concedes that the error was inadvertent.            
          We do not believe that an underpayment resulting from an                    
          inadvertent computational error is an appropriate case for relief           
          from joint liability under section 6015(f).                                 
               4.   Conclusion                                                        
               Considering all the facts and circumstances, we hold that it           
          is not inequitable to hold petitioner liable for the unpaid tax             
          (i.e., resulting from the erroneous withholding amount and the              
          resulting erroneous refund) for 1999.  We determine that                    
          respondent’s denial of relief under section 6015(f) was not an              
          abuse of discretion and that, on the basis of all the facts and             
          circumstances, it would not be inequitable to hold petitioner               
          liable for the underpayment of tax for 1999.                                

                                                       Decision will be               
                                                  entered for respondent.             





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