Carolyn A. Glenn - Page 20

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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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