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Conclusion
Petitioner has presented a strong case for relief from joint
tax liability on the basis of the factors promulgated by the
Commissioner in Rev. Proc. 2000-15, sec. 4.03. Most of those
factors favor granting petitioner relief. Most significantly,
petitioner would suffer extreme economic hardship if relief were
denied. After considering all of the facts and circumstances, we
find that it would be inequitable to hold petitioner liable for
payment of the outstanding tax liabilities for all years at
issue. Accordingly, we hold that respondent abused his
discretion in denying petitioner equitable relief from joint and
several liability under section 6015(f).
To reflect the foregoing,
Decision will be entered
for petitioner.
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Last modified: November 10, 2007