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employed during the years at issue and failed to establish that
she would be unable to pay basic living expenses if she were
required to pay the outstanding tax liabilities for 1998 and
1999.
Upon consideration of all of the facts and circumstances,
the Court holds that respondent’s determination to deny
petitioner relief under section 6015(f) was not an abuse of
discretion. Weighing all of the factors in this case both
supporting and opposing granting relief to petitioner, the Court
is satisfied that it is not inequitable to deny petitioner relief
under section 6015(f).
Decision will be entered
for respondent.
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Last modified: November 10, 2007