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Court concludes that there was no abuse of discretion by
respondent in denying petitioner’s request for equitable relief
under section 6015(f) for the underpayment or the deficiency. To
the extent not addressed herein, other considerations are without
merit or unnecessary to reach. The Court, therefore, sustains
respondent’s determination that petitioner is not entitled to
relief from joint and several liability pursuant to section
6015(b), (c), or (f).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011