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The record in the instant case does not demonstrate that it
would be inequitable to deny petitioner relief. Petitioner had
knowledge of the item giving rise to the deficiency and failed to
fulfill her duty of inquiry when she signed the return without
any review. Butler v. Commissioner, supra. We do not believe
petitioner’s actions were reasonable under the circumstances.
Petitioner has also failed to prove that she will suffer economic
hardship if relief is not granted. See sec. 301.6343-1(b)(4),
Proced. & Admin. Regs. (defining economic hardship as causing the
taxpayer to be unable to pay his or her basic living expenses).
Accordingly, we conclude that it was not an abuse of discretion
for respondent to deny petitioner relief under section 6015(f).
We have considered all of petitioner’s contentions. To the
extent not addressed herein, those contentions are without merit
or unnecessary to reach.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011