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economic hardship, the question of benefit from the underpayment
and refund, the absence of a legal obligation of Mr. Shattun to
pay the tax, and petitioner’s mental condition. The factors
weighing against relief are petitioner’s actual knowledge of the
item giving rise to the deficiency and her unexplained failure to
timely file tax returns for 2002 and 2003. On this record we
conclude that respondent’s denial of equitable relief for
petitioner from joint Federal income tax liability for 2000 under
section 6015(f) was not an abuse of discretion.
To reflect the foregoing,
Decision will be
entered for respondent.
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