- 19 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Last modified: May 25, 2011