- 24 -
Conclusion: Weight of the Factors
Although the decision is close, the Court concludes that the
Appeals officer did not act arbitrarily, capriciously, or without
sound basis in fact, nor is there anything “fundamentally wrong”
with the IRS’s determination. See Johnson v. J.B. Hunt Transp.,
Inc., 280 F.3d at 1131. Consequently, the Court concludes that
respondent’s denial of relief with respect to 1998 through 2002
was not an abuse of discretion and that it would not be
inequitable to hold petitioner liable for the unpaid taxes and
the $704.88 portion of the deficiency with respect to 2000.
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 25
Last modified: March 27, 2008