Patricia S. Makalintal - Page 26

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               During 1986, 1987, and 1988, petitioner's standard of living           
          and level of support from Mr. Makalintal did not significantly              
          increase in comparison to the standard of living and the level of           
          support in prior years.                                                     
               In 1990, after Mr. Makalintal and petitioner divorced,                 
          petitioner received from Mr. Makalintal approximately $135,000              
          for living expenses and for support of the children.  Petitioner            
          was accustomed to a high standard of living, and the $135,000 was           
          at least consistent with her standard of living and did not                 
          provide petitioner a significant benefit beyond her normal                  
          support.  Aside from the $10,553 that petitioner received from              
          sale of the Greenbrae home, petitioner did not receive any of the           
          additional property, alimony, or child support to which she was             
          entitled under the property settlement agreement.                           
               Throughout their marriage and during 1986, 1987, and 1988,             
          Mr. Makalintal physically abused petitioner, and petitioner lived           
          in constant fear of him.  Mr. Makalintal and petitioner are now             
          divorced.  Mr. Makalintal apparently is now living in the                   
          Philippines and refused to provide petitioner with certain                  
          records relevant to the issues in these cases.                              
               Denying petitioner innocent spouse relief in these cases               
          would likely cause very substantial hardship to petitioner.                 
          Mr. Makalintal has abandoned petitioner and left her to deal with           
          substantial income tax understatements that are attributable to             
          him.  Petitioner has had to pursue further education to support             




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