- 61 -
On the record before us, we find that petitioner would
suffer an economic hardship if she were required to pay the 1982
total liability.
With respect to the tax compliance factor, petitioner
contends, and respondent does not dispute, that she complied with
the tax laws for her taxable years following her taxable year
1982.
Based upon our examination of the entire record before us,
we find that, taking into account all the facts and circum-
stances, it is inequitable to hold petitioner liable for the
deficiency in, and additions to, tax (as well as interest thereon
as provided by law) attributable to the understatement in the
1982 joint tax return. On that record, we further find that
petitioner satisfies section 6015(b)(1)(D) for her taxable year
1982.
Conclusion
Based upon our examination of the entire record before us,
we find that petitioner is entitled to relief under section
6015(b) with respect to her taxable year 1982.35
We have considered all of the parties’ contentions and
arguments that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
35In light of our finding that petitioner is entitled to
relief under sec. 6015(b) with respect to her taxable year 1982,
we need not address petitioner’s alternative claim for relief
under sec. 6015(f) for that year.
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