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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 are
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