- 18 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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