Cheryl McKnight - Page 23

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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                    
               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               

               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                   
               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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