Lisa Marie Pierce - Page 17

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          to examine the return and verify that payment was sent with the             
          return.                                                                     
               Petitioner has not provided this Court with credible                   
          evidence to show that she reasonably believed that Mr. Pierce               
          would pay the tax liability at the time she signed the return.              
          As a result, the Court finds that petitioner had constructive               
          knowledge that the liability would not be paid for 1994.                    
               Petitioner also has not shown that she will suffer economic            
          hardship if relief is denied.  Petitioner in fact concedes that             
          she can afford to pay the unpaid tax liability but argues that              
          only her 1996 financial situation, not her current one, is                  
          relevant.  This rationale is apparently the reason that                     
          petitioner submitted a 1996 financial statement and not a current           
          one.  Thus, this Court holds that petitioner will not suffer                
          economic hardship if relief is denied.                                      
               In her petition, petitioner alleges that Mr. Pierce,                   
          throughout their marriage, engaged in "brainwashing" as a form of           
          spousal abuse.  Her position is that the abusive behavior is a              
          factor that ought to sway the Court to grant her relief from                
          joint and several liability.  Petitioner's allegation, however,             
          is unsupported by any evidence.  The Court, therefore, does not             
          consider this factor.                                                       
               Finally, petitioner's assertion that Mr. Pierce was                    
          generally deceptive in connection with their finances is                    






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Last modified: May 25, 2011