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6. Compliance with income tax laws: Petitioner was up-to-
date with tax returns at the time respondent denied relief. This
factor is neutral.
Two other factors, abuse and the mental or physical health
of petitioner, can weigh only in favor of relief. Respondent
found that these factors do not apply to this case. The Court
has found nothing in the record relating to these factors to
indicate that respondent’s evaluation is incorrect. We therefore
agree with respondent’s determination that these factors are
neutral.
Respondent determined that the factor (petitioner’s divorce)
that favors relief is outweighed by the factors (her knowledge of
the income and her failure to demonstrate economic hardship) that
favor liability. Considering all the facts and circumstances of
this case, we hold that petitioner has not demonstrated that
respondent acted arbitrarily, capriciously, or without sound
basis in fact and that respondent did not abuse his discretion in
denying petitioner relief under section 6015(f).
Conclusion
Petitioner is not entitled to relief under section 6015(b)
or (c), and respondent did not abuse his discretion in denying
relief under section 6015(f).
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: November 10, 2007