Dwan A. Thomas - Page 12

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          economic hardship if relief from the liability were not granted.            
               The Court finds, considering all the facts and                         
          circumstances, that respondent did not abuse his discretion in              
          denying petitioner equitable relief from joint and severable                
          liability under section 6015(f).                                            
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          





























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