T.C. Memo. 2007-167 UNITED STATES TAX COURT CYNTHIA K. BEATTY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22047-04. Filed June 27, 2007. Caroline D. Ciraolo, for petitioner. James H. Harris, Jr., for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION CHIECHI, Judge: This case arises from a request for equita- ble relief (relief) under section 6015(f).1 We must decide whether respondent abused respondent’s discretion in denying 1All section references are to the Internal Revenue Code in effect at all relevant times. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007