- 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...)
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