- 37 - Mrs. Dunne had full access to petitioners’ joint checking and savings accounts, and she offered no evidence that Mr. Dunne deposited the dividends he received from FRC into a separate account that she could not access. Since it appears Mrs. Dunne financially benefited as much as did Mr. Dunne from ownership of FRC and from avoiding taxation on his share of income, the significant benefit factor does not favor Mrs. Dunne’s position. See Richardson v. Commissioner, T.C. Memo. 2006-69, affd. 509 F.3d 736 (6th Cir. 2007). Furthermore, Mrs. Dunne has offered no evidence that Mr. Dunne concealed anything from her or committed any wrongdoing. We may also consider factors used in determining “inequity” in the context of section 6015(f). Juell v. Commissioner, T.C. Memo. 2007-219. However, because we find without relying on the other factors that Mrs. Dunne has not shown that she is eligible for relief under section 6015(b), and because we find that taken together those factors weigh against relief for Mrs. Dunne, as discussed below, we need not consider them here also. Section 6015(f) provides that the Secretary may relieve an individual of joint and several liability if relief is not available to the individual under section 6015(b) or (c) and it is inequitable to hold the individual liable for any deficiency taking into account all the facts and circumstances under procedures prescribed by the Secretary. These procedures arePage: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 NextLast modified: March 27, 2008