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checking account shows that it contains enough to pay only a tiny
fraction of the deficiency for 1983.
Respondent contends that petitioner will not suffer economic
hardship if relief is denied because her children and family pay
some of her and Ferrarese’s living expenses. Respondent
apparently assumes that petitioner’s children would pay the 1983
taxes, and that, as a result, petitioner would suffer no hardship
if held jointly liable for those taxes. We disagree. First,
there is no evidence that petitioner’s children would or could
pay the 1983 taxes; second, we believe it would be a hardship to
compel petitioner to ask her children to do so. We conclude that
petitioner will suffer economic hardship if she is not relieved
of joint liability.
2. Significant Benefit
Respondent contends that petitioner significantly benefited
from the embezzlement income omitted from petitioner’s and
Ferrarese’s return for 1983. We disagree. In Ferrarese I, we
found that petitioner’s expenditures during 1981-83 were neither
unusual nor lavish and did not suggest that petitioner
significantly benefited from the embezzlement income.
Petitioner’s testimony in this case was consistent with our
findings in her prior case, and respondent did not cross-examine
petitioner or offer contrary evidence. We conclude that
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