Mary A. George - Page 19

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          $7,500 for the 6 years in question.8  We conclude that                      
          petitioner’s contention has no merit because petitioner filed               
          joint returns with Mr. George, and we must base our decision on             
          the actual facts of the instant case.  Consequently, because a              
          significant portion of the unpaid liability is attributable to              
          petitioner, the liability attribution negative factor weighs                
          against relief.                                                             
               The knowledge negative factor weighs against relief.  As               
          noted above, we believe that petitioner knew or had reason to               
          know that the reported liabilities would be unpaid at the time              
          petitioner signed the returns.                                              
               The significant benefit negative factor weighs against                 
          relief.  “Significant benefit” for purposes of section                      
          6015(b)(1)(D) is defined in section 1.6015-2(d), Income Tax                 
          Regs.:                                                                      
                    (d) Inequity.  All of the facts and circumstances                 
               are considered in determining whether it is inequitable                
               to hold a requesting spouse jointly and severally                      
               liable for an understatement.  One relevant factor for                 
               this purpose is whether the requesting spouse                          
               significantly benefitted, directly or indirectly, from                 
               the understatement.  A significant benefit is any                      
               benefit in excess of normal support.  Evidence of                      
               direct or indirect benefit may consist of transfers of                 
               property or rights to property, including transfers                    
               that may be received several years after the year of                   
               the understatement.  Thus, for example, if a requesting                
               spouse receives property (including life insurance                     


               8Petitioner reaches this amount by subtracting withholding             
          of $3,750 from $4,250 of estimated annual tax liability and                 
          adding penalties and interest.                                              





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