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Court concludes that there was no abuse of discretion in denying
petitioner’s request for relief under section 6015(b), (c), or
(f) for taxable years 2002 and 2003. To the extent not addressed
herein, other considerations are without merit or unnecessary to
address. The Court, therefore, sustains respondent’s
determination that petitioner is not entitled to relief from
joint liability pursuant to section 6015(b), (c), or (f) for
taxable years 2002 or 2003.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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