- 40 - 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 federalPage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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