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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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Last modified: May 25, 2011