Ann E. Bartak - Page 30

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          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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