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Compliance With Federal Tax Laws
On December 31, 2001, petitioner and Mr. Butner filed late a
joint income tax return for the taxable year 2000 that showed a
tax liability of $7,807 that was unpaid. In addition, during
2000, petitioner received wages of $16,952 from Mr. Butner for
secretarial work, from which no income tax was withheld. Fur-
thermore, on January 6, 2003, petitioner filed late an income tax
return for the taxable year 2001 that showed a tax liability of
$141, which she paid at that time.
Petitioner failed to comply with the income tax laws for
certain taxable years following the taxable years to which her
request for relief relates. This factor weighs against granting
relief.
In addition, petitioner has not established any other
factors not set forth in Revenue Procedure 2000-15 that favor
granting relief to her.
In conclusion, under the facts and circumstances in the
instant case, we hold that respondent did not abuse respondent’s
discretion in denying equitable relief under section 6015(f) to
petitioner.
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
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Last modified: November 10, 2007