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income tax liabilities reported on the joint income tax returns
for 1990 through 1995 were, in part, attributable to assets that
she jointly owned with intervenor. Consequently, the attribution
factor weighs against granting petitioner relief.
Based on our examination of the facts and circumstances in
this case, the factors in Rev. Proc. 2000-15, sec. 4.03, 2000-1
C.B. at 448, weighing against granting petitioner relief outweigh
those weighing in favor of granting her relief. Accordingly, we
conclude that respondent did not abuse respondent’s discretion by
acting arbitrarily, capriciously, or without sound basis in fact
in denying petitioner’s request for equitable relief under
section 6015(f).
To reflect the foregoing,
Decision will be entered
for respondent.
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