Connie A. Washington v. Commissioner of Internal Revenue

Summary

The court held that the Commissioner abused his discretion by denying petitioner equitable relief from the unpaid 1989 joint-return liability under section 6015(f). Petitioner lacked knowledge or reason to know that the liability would remain unpaid, would suffer substantial economic hardship, and did not benefit significantly from the unpaid tax. The court further held that section 6015 applied to the entire preexisting 1989 liability and authorized refunds of qualifying payments, subject to the statutory limitations governing refund claims.