Maureen Monsour - Page 67

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          Nonetheless, on the record before us, we find that petitioner has           
          failed to establish the amount that she and Mr. Monsour expended            
          annually for their normal support before, during, and after the             
          taxable years at issue.  On that record, we further find that               
          petitioner has failed to carry her burden of persuading us that             
          she did not significantly benefit beyond normal support from the            
          items giving rise to the deficiency with respect to each of the             
          taxable years 1989, 1991, 1992, and 1993.                                   
               On the record before us, we find that petitioner has failed            
          to carry her burden of establishing that the significant benefit            
          negative factor set forth in section 4.03(2)(c) of Revenue Proce-           
          dure 2000-15 is not present in this case.                                   
               With respect to the noncompliance negative factor set forth            
          in section 4.03(2)(e) of Revenue Procedure 2000-15, petitioner              
          contends that she “has followed all of the tax laws in the years            
          since 1993.”  We have found that at the time of the trial in this           
          case in September 2003 petitioner and Mr. Monsour had an unpaid             
          liability of $60,000 with respect to their 1998 joint return.  On           
          the record before us, we find that petitioner has failed to carry           
          her burden of establishing that the noncompliance negative factor           
          set forth in section 4.03(2)(e) of Revenue Procedure 2000-15 is             
          not present in this case.                                                   
               With respect to the legal obligation negative factor set               
          forth in section 4.03(2)(f) of Revenue Procedure 2000-15, we have           






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