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Rev. Proc. 2003-61, sec. 4.03(2), elaborates further on
various factors to consider in reviewing requests for section
6015(f) equitable relief. No one factor will control, and all
relevant factors are to be considered and weighed. The factors
set forth in Rev. Proc. 2003-61, supra, are not intended to be
exhaustive. Rev. Proc. 2003-61, supra.
We review respondent’s denial of section 6015(f) equitable
relief for an abuse of discretion. Hopkins v. Commissioner,
supra at 87; Cheshire v. Commissioner, 115 T.C. 183, 198 (2000),
affd. 282 F.3d 326 (5th Cir. 2002).
Section 6015(b) Relief
As explained, section 6015(b) relief is available only for
tax deficiencies, not underpayments. Respondent correctly
concluded that petitioner fails to qualify for relief under
section 6015(b) as to her joint liability for the $6,452 tax
deficiency.
Petitioner had knowledge of the interest on the home
mortgages and of the various business activities and income of
MGI. Cf. sec. 1.6015-3(c)(4), Example (1), Income Tax Regs.
Although John made all the financial decisions, petitioner
tracked and paid the bills, including the mortgage payments.
Petitioner does not qualify for section 6015(b) relief for
any portion of the tax deficiency at issue herein.
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