Cheryl McKnight - Page 22

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               Respondent correctly concluded that this factor weighs                 
          against granting relief to petitioner.                                      

          (3) Abuse                                                                   
               Respondent minimized the abuse petitioner suffered.  An                
          alternate writeup accompanying respondent’s Appeals Office                  
          determination states:                                                       

               The abuses outlined in the claimant’s arguments do not                 
               appear to have been more than her willingness to hold a                
               subservient role in the relationship.  There is no                     
               indication that she was called names, ridiculed,                       
               criticized or belittled.                                               

               We disagree.  The material petitioner submitted to                     
          respondent and which is found in the administrative record in               
          this case, as well as vivid and credible trial testimony herein,            
          thoroughly establishes the extensive and severe abuse petitioner            
          suffered from John.                                                         
               Due to the severity of the abuse suffered by petitioner,               
          this factor strongly favors granting relief to petitioner.                  
               Further, John’s extensive abuse of petitioner mitigated                
          petitioner’s reason to know that John might not pay the                     
          underpayment.  See Rev. Proc. 2003-61, sec. 4.03(2)(b)(i).                  

          Overton’s Son                                                               
               Respondent also considered the impact on Overton’s son of              
          granting petitioner equitable relief.  Respondent concluded that            

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