- 41 - income tax liabilities that she owes, but for the single tax year in question.” The parties stipulated that “For tax years * * * 1996 through 2000, petitioner filed income tax returns”. Respon- dent does not contend that petitioner did not pay any Federal income tax shown due in each such return. With respect to taxable year 2001, the record contains an unsigned Form 1040 for that year.29 On the record before us, we find that petitioner has established that she has made a good faith effort to comply with the Federal income tax laws following taxable year 1995. We further find on that record that petitioner has carried her burden of establishing that the noncompliance negative factor is not present in the instant case. With respect to the legal obligation negative factor set forth in section 4.03(2)(f) of Revenue Procedure 2000-15, we found above that the legal obligation positive factor set forth in section 4.03(1)(e) of Revenue Procedure 2000-15 is a neutral factor in the instant case. On the record before us, we further find that the legal obligation negative factor set forth in section 4.03(2)(f) of that revenue procedure is a neutral factor in the instant case. On the record before us, we find that petitioner has failed to carry her burden of establishing any other factors with 29The record does not establish that petitioner had filed the unsigned Form 1040 for 2001 as of May 14, 2002, the date of the trial in this case.Page: 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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