Donna M. Keitz - Page 18

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          Federal tax laws at least since 1996, she did not know or have              
          reason to know Mr. Keitz would not pay the unpaid tax for 1996,             
          and Mr. Keitz bears the legal obligation to pay the tax.  The               
          neutral factors include petitioner's compliance with the tax laws           
          and lack of spousal abuse.  The Court determines that                       
          respondent's denial of relief under section 6015(f) was an abuse            
          of discretion, and that, on the basis of the facts and                      
          circumstances, it would be inequitable to hold petitioner liable            
          for the underpayment of tax for 1996.                                       
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for petitioner.                          


























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