- 19 - 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).Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011