Yvonne C. Lopez - Page 19

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          tax obligations in the years subsequent to those in issue here.             
          Consequently, we conclude this negative factor does not apply.              
          See Ewing v. Commissioner, supra at 46-47.                                  
                    f.  Requesting Spouse’s Legal Obligation                          
               With respect to the positive counterpart to this factor, we            
          concluded that Mr. Cowdery, rather than petitioner, bears the               
          legal obligation to pay the liabilities at issue in this case.              
          Consequently, this negative factor does not apply.                          
               3.   Conclusion                                                        
               Three factors weigh in favor of granting petitioner relief.            
          Although three factors also weigh against granting petitioner               
          relief, the knowledge or reason to know factor weighs heavily               
          against relief.  All other factors are neutral.  After                      
          considering all the facts and circumstances, we find that                   
          respondent did not abuse his discretion in denying petitioner               
          equitable relief from joint and several liability under section             
          6015(f).                                                                    
               We have carefully considered all remaining arguments made by           
          the parties for results contrary to those expressed herein and,             
          to the extent not discussed above, find those arguments to be               
          irrelevant, moot, or without merit.                                         
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          






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