- 10 - 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 wasPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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