- 24 - Inc., 280 F.3d 1125, 1131 (2002). Consequently, respondent’s denial of relief was not an abuse of discretion, and it is not inequitable to hold petitioner liable for the unpaid taxes. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25Last modified: March 27, 2008