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particular case. Rather, all factors will be
considered and weighed appropriately. The list is not
intended to be exhaustive.
As discussed next, none of the factors used by the
Commissioner in making section 6015(f) determinations supports
respondent’s determination in this case.
1. Petitioner’s Marital Status
Petitioner was still married to Mr. Wiwi at the time of
trial. Respondent determined without further explanation, but
did not otherwise argue before the Court, that the marital status
factor weighs against petitioner. We conclude that this factor
is neutral.
2. Spousal Abuse
Mr. Wiwi did not abuse petitioner. Respondent does not
contend that the spousal abuse factor weighs against petitioner.
We conclude that this factor is neutral.
3. Significant Benefit
Respondent does not argue that petitioner significantly
benefited from Mr. Wiwi’s underpayment of tax for 1995.
Petitioner has paid more than one half of her and Mr. Wiwi’s
expenses since the time they were married. Petitioner has not
received any income or other financial benefit from Mr. Wiwi.
Petitioner’s financial situation worsened after 1995 due to Mr.
Wiwi’s financial problems. We conclude that petitioner did not
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