- 19 - bounds of normal support. See, e.g., Foley v. Commissioner, T.C. Memo. 1995-16. In evaluating the equity holding a spouse liable under section 6013(e), we also consider the probable future hardship on the spouse seeking relief if that spouse is required to pay the tax. Sanders v. United States, 509 F.2d at 171 n.16; Makalintal v. Commissioner, T.C. Memo. 1996-9. The evidence before the Court indicates that there will be substantial hardships if we deny relief in this case. Petitioner's standard of living has decreased significantly from the time of the divorce. In 1994, petitioner reported adjusted gross income of less than $13,000. Further, petitioner has periodically received financial assis- tance from her elder son. Respondent points out that petitioner received substantial assets in the divorce. However, the property located at Hangman Valley Road, by far the most signifi- cant asset petitioner received in the divorce, was sold in 1989 for barely more than 50 percent of its assigned value in the property settlement agreement. Nonetheless, respondent argues that it would not be inequitable to hold petitioner liable because, under the property settlement agreement incident to the divorce, Thomas Dillon indemnified petitioner against any losses resulting from tax liabilities arising from returns filed prior to 1987. The record indicates, however, that Mr. Dillon does not have the money toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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