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6. Compliance With Income Tax Laws
In his pretrial memorandum, respondent contends that
“petitioner has not demonstrated that she made a good faith
effort to comply with federal income tax laws.”
To the contrary, in her pretrial memorandum, petitioner
contends that she has complied with the income tax laws.
Respondent did not produce any evidence that supported his
contention. Therefore, we consider this factor neutral.
7. Abuse
Petitioner conceded that she was not abused by Mr. Glenn and
that she was not coerced into executing the 2001 joint Federal
income tax return. Lack of spousal abuse is a factor listed in
Rev. Proc. 2003-61, sec. 4.03(2)(b)(i), that will weigh in favor
of equitable relief if found but will not weigh against equitable
relief if not present in a case. Therefore, this factor is
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).
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