E. Carolyn Mellen - Page 40




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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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