Wendy L. Chadwick - Page 24

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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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