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outweighed by the significant benefit petitioner received from
the underpayment, her knowledge or reason to know that the
reported liability would be unpaid, and her failure to
demonstrate economic hardship. Based on the above, we find that
petitioner has failed to carry her burden of showing respondent
abused his discretion in denying her equitable relief under
section 6015(f).
In reaching our holding herein, we have considered all
arguments made, and, to the extent not mentioned above, we
conclude that they are moot, irrelevant, or without merit.
To reflect the foregoing and respondent’s concession
regarding petitioner’s 1997 tax year,
An appropriate
decision will be entered.
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Last modified: November 10, 2007