Vicki Jo James - Page 12

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          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.                                                     














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