Sandrus L. Collier - Page 38




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          knowledge or reason to know negative factor set forth in section            
          4.03(2)(d) and (b), respectively, of that revenue procedure are             
          not present in the instant case.                                            
               With respect to the attribution negative factor set forth in           
          section 4.03(2)(a) of Revenue Procedure 2000-15, we have found              
          above that Ms. Collier has failed to carry her burden of showing            
          that the unpaid liability for each of the years at issue is                 
          solely attributable to Mr. Collier’s allegedly having claimed an            
          excessive number of withholding allowances.  Ms. Collier prof-              
          fered no reliable evidence to show that no portion of the unpaid            
          liability for each of the years at issue is attributable to her.            
          On the record before us, we find that Ms. Collier has failed to             
          carry her burden of establishing that with respect to each of the           
          years at issue the attribution negative factor set forth in                 
          section 4.03(2)(a) of Revenue Procedure 2000-15 is not present in           
          the instant case.                                                           
               With respect to the significant benefit negative factor set            
          forth in section 4.03(2)(c) of Revenue Procedure 2000-15, Ms.               
          Collier contends on brief that she did not significantly benefit            
          from the unpaid assessment for each of the years at issue be-               
          cause, inter alia:                                                          
               [Mr. Collier] failed to support petitioner and their                   
               son adequately, resulting in her having to borrow money                
               from friends on occasion.  Moreover, there were times                  
               that petitioner could not even pay the household bills                 
               at times due to her husband’s controlling of the fam-                  
               ily’s money.  [Internal references omitted.]                           





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