T.C. Memo. 2005-220
UNITED STATES TAX COURT
ELEANOR SIMON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20258-04. Filed September 21, 2005.
Jeffrey A. Collins, for petitioner.
Steven M. Webster, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: This case arises from a request for equita-
ble relief (relief) under section 6015(f)1 with respect to peti-
tioner’s taxable year 1998. We must decide whether respondent
abused respondent’s discretion in denying petitioner such relief.
We hold that respondent did not abuse respondent’s discretion.
1All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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