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The facts that weigh against granting relief, such as
petitioner’s lack of financial hardship, are insufficient to deny
petitioner relief. Petitioner satisfies section 6015(b)(1)(D).
Section 6015(c) and (f)
Because petitioner qualifies under section 6015(b) for
relief from joint liability with regard to 100 percent of the tax
deficiencies relating to the Hoyt partnership investments, we
need not address petitioner’s eligibility for relief under
subsections (c) and (f) of section 6015.
To reflect the foregoing,
Decision will be entered for
petitioner.
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Last modified: November 10, 2007