- 9 -
return. Petitioner testified that even though Mr. Meadows assured
her that he would properly manage their tax obligations, she was
aware that she could not trust him to actually do so. Moreover,
petitioner testified that Mr. Meadows had always prepared and
filed her tax returns, both the joint and separate returns, and
that several years before 1999, respondent had garnished her
wages.
Nothing in petitioner’s testimony establishes that petitioner
believed that Mr. Meadows would pay the reported tax liability.
Even if we could find (which we do not) that petitioner believed
that Mr. Meadows would pay the reported tax liability, we could
not find that her belief was reasonable. On the contrary,
petitioner’s experience in relying on Mr. Meadows to pay income
taxes had resulted in the garnishing of her wages.
Further, we do not find that petitioner will suffer economic
hardship if she is not granted innocent spouse relief. The record
shows that petitioner earned more than $46,000 in 2005. The
unpaid tax that respondent seeks to recover, including interest as
of the date of trial, is approximately $2,300. Petitioner did not
provide any supporting documentation, but she testified that she
contributes to the support of her young adult children and her
elderly parents. Even if we were persuaded that petitioner’s
living expenses include the cost of supporting adult children and
elderly parents, these costs were not quantified, and we cannot
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011