- 11 - section makes clear, no single factor is to be determinative in any particular case–-all factors are to be considered and weighed appropriately, and the list of factors is not intended to be exhaustive. We see little point in listing and discussing each factor set forth in section 4.03 of the revenue procedure. Respondent has adequately done so in his supporting statement denying petitioner’s request for section 6015(f) relief. Suffice it to say that respondent has considered each and every one of the factors listed in section 4.03 of the revenue procedure. Although we might not entirely agree with respondent’s conclusion with respect to each, we cannot say that respondent’s determination to deny petitioner’s request for section 6015(f) relief for any year in issue is an abuse of discretion. Reviewed and adopted as the report of the Small Tax Division. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011