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these factors will not weigh against equitable relief. See Rev.
Proc. 2003-61, sec. 4.03(2)(b), 2003-2 C.B. at 299.
There are two factors weighing for and two factors weighing
against relief for petitioner. It is also clear from the record
that petitioner was the victim of cruel circumstances. Although
the Court might not have denied relief in this case, the Court
cannot conclude on this record that the IRS exercised its
discretion arbitrarily, capriciously, or without sound basis in
fact when it denied the requested relief under section 6015(f).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: March 27, 2008