- 30 - to the deficiency, (5) Mr. Bartak did not have an obligation to pay the liability pursuant to a divorce decree, and (6) the items giving rise to the deficiencies are not attributable solely to Mr. Bartak. See Washington v. Commissioner, 120 T.C. 137, 147 (2003). Additionally, the following factors weighing against relief are present:10 (1) The items giving rise to the deficiencies are attributable to petitioner, (2) petitioner knew or had reason to know of the item giving rise to the deficiency, and (3) petitioner will not suffer economic hardship. Id. As we found, supra, the items giving rise to the deficiencies are attributable to petitioner, and she knew or had reason to know of the understatements under the Price standard. Petitioner’s tax liabilities for 1980 through 1986 totaled $82,680. Even if we were to include the interest due on that liability as of April 2002 (the most current information available in the record), petitioner and Mr. Bartak have hundreds of thousands of dollars in assets in excess of this amount. As of February 2003, based on the information she provided, the assets listed on the Form 433-A had a total current fair market value of approximately $675,000.11 Additionally, after 10 The absence of factors weighing against equitable relief does not weigh in favor of granting relief--they are neutral. Doyel v. Commissioner, T.C. Memo. 2004-35; see Washington v. Commissioner, 120 T.C. 137, 149 (2003). 11 In reaching this figure, we used the following figures: (continued...)Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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