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of the years 1994 and 1997 through 2001.
On the record before us, we find that petitioner has failed
to persuade us that she did not significantly benefit beyond
normal support from the $9,719 of Federal income tax not paid for
taxable year 1995. On that record, we further find that peti-
tioner has failed to carry her burden of establishing that the
significant benefit negative factor set forth in section
4.03(2)(c) of Revenue Procedure 2000-15 is not present in the
instant case.
With respect to the economic hardship negative factor set
forth in section 4.03(2)(d) of Revenue Procedure 2000-15, we
found above that petitioner failed to carry her burden of estab-
lishing that the economic hardship positive factor set forth in
section 4.03(1)(b) of that revenue procedure is present in the
instant case. On the record before us, we further find that
petitioner has failed to carry her burden of establishing that
the economic hardship negative factor set forth in section
4.03(2)(d) of Revenue Procedure 2000-15 is not present in the
instant case.
With respect to the noncompliance negative factor set forth
in section 4.03(2)(e) of Revenue Procedure 2000-15, petitioner
contends that she “has filed all federal income tax returns
required of her since she entered the work force after her
graduation from high school” and that “She has paid all federal
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