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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.
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