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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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Last modified: May 25, 2011