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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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