Linda S. Dillon - Page 19

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          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 to              





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