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granted, and had to deal with various problems associated with
Mr. Foor’s alcoholism and her mother’s illness. Respondent
further admits that petitioner did not significantly benefit from
the unpaid taxes and has made a good faith effort to comply with
the Federal income tax laws in the years following the years at
issue, and there were no perceptible asset transfers between
petitioner and Mr. Foor.
The revenue agents’ workpapers reflect that an additional
reason that equitable relief was not granted was that they
believed petitioner’s withholding was inadequate and did not
cover her share of the tax liabilities. At trial, Mr. Petroff
testified that he reviewed the tax returns and Forms W-2, Wage
and Tax Statement, for 1988, 1990, and 1992 in making this
determination, but that he did not review the returns or Forms W-
2 for any earlier years. The years in issue are 1983, 1984,
1985, 1987, 1990, and 1991. Thus, Mr. Petroff’s determination
that petitioner’s wages were underwithheld for the other 5 years
in issue was based on his assumption that there was a continuous
pattern of inadequate withholding.
Mr. Petroff also testified that a requesting spouse cannot
be relieved of liability for tax attributable to her own income
under the rules for relief from joint and several liability.
Petitioner’s information submissions to the revenue agents and
her testimony reflect that she believed that her withholding was
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