Lisa Marie Pierce - Page 14

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          112 T.C. 19, 23 (1999); Mailman v. Commissioner, 91 T.C. 1079,              
          1082-1084 (1988).                                                           
               In the case of a liability that was reported but not paid,             
          the fact that the requesting spouse did not know and had no                 
          reason to know that the liability would not be paid is a factor             
          weighing in favor of granting relief.  Rev. Proc. 2000-15, sec.             
          4.03(1)(d), 2000-1 C.B. at 449.  By contrast, the fact that the             
          requesting spouse knew or had reason to know that the reported              
          liability would be unpaid is an extremely strong factor weighing            
          against relief.  Rev. Proc. 2000-15, sec. 4.03(2)(b), 2000-1 C.B.           
          at 449.  Respondent contends that petitioner did not prove that             
          she did not know or did not have reason to know that the unpaid             
          1994 tax liability would not be paid at the time the return was             
          filed.                                                                      
               The taxpayer has a "duty of inquiry" to determine the amount           
          of her tax liabilities.  See Price v. Commissioner, 887 F.2d 959,           
          965 (9th Cir. 1989), revg. an Oral Opinion of this Court; Butler            
          v. Commissioner, 114 T.C. 276, 284 (2000).  A taxpayer is not               
          relieved of her duty of inquiry because she relied on her husband           
          to take care of the returns.  See Hayman v. Commissioner, 992               
          F.2d 1256, 1262 (2d Cir. 1993), affg. T.C. Memo. 1992-228.  A               
          taxpayer can not obtain the benefits of relief from joint and               
          several liability simply because she turned a "blind eye" by                
          signing a blank return and then failed to make further inquiry              






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