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benefitted (beyond normal support) from the unpaid liability or
items giving rise to the deficiency.” Due to the use of Mr.
Tillotson’s income to pay household and living expenses during
taxable years 1995, 1997, and 1998, we find that petitioner did
not benefit “beyond normal support” from the income which led to
the income tax liabilities for taxable years 1995, 1997, and
1998. Therefore, this factor is a neutral factor.
8. Noncompliance With Federal Income Tax Laws
There is no evidence in the record as to this factor.
Therefore, we consider this factor neutral.
Conclusion
The factors that weigh against granting relief to petitioner
outweigh those factors favoring relief. Therefore, under these
facts and circumstances, we hold that respondent did not abuse
his discretion in denying equitable relief to petitioner under
section 6015(f).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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