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because granting relief to petitioner might reduce John’s estate
and the inheritance Overton’s son might be entitled to receive,
this factor weighed against granting equitable relief to
petitioner.
Although sympathetic to the potential adverse financial
effect of our decision herein on Overton’s son, we do not find
this factor particularly relevant, nor does it outweigh the
factors which weigh in favor of granting petitioner equitable
relief.6
Conclusion
Respondent correctly concluded that petitioner does not
qualify for relief under section 6015(b).
Respondent correctly concluded that petitioner qualified
generally for relief under section 6015(c); however, we hold that
petitioner qualified for relief with regard to the entire $6,452
deficiency, not just 50 percent thereof.
Respondent incorrectly rejected petitioner’s request for
section 6015(f) equitable relief as to the 50 percent of the
$17,516 income tax underpayment nominally attributable to
petitioner.
We agree with respondent’s conclusion that petitioner is
entitled to section 6015(f) equitable relief as to 50 percent of
6 John’s third wife, with proceeds from insurance on John’s
life, provided Overton’s son with a $30,000 trust fund.
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