- 24 - 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 notPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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