Jeanine T. Foor - Page 10

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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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