Andrea J. Vuxta - Page 9

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          passed before the bankruptcy petition was filed.  The 1989 return           
          was prepared by Mr. Vuxta.  Petitioner was not the primary wage             
          earner and was not involved in Mr. Vuxta’s business.  It does not           
          appear from the record that petitioner knew or had reason to know           
          that such liability would be unpaid at the time the 1989 return             
          was filed on September 17, 1990.                                            
               c.  Significant Benefit                                                
               The record is not clear as to whether petitioner has                   
          significantly benefited (beyond normal support) from the unpaid             
          tax liabilities.                                                            
               d.  Lack of Economic Hardship                                          
               As we indicated earlier, petitioner has not shown that she             
          will suffer economic hardship if relief is not granted.  Her                
          debts were discharged in bankruptcy on May 23, 1997, and                    
          petitioner received the proceeds of Mr. Vuxta’s 401(k) plan after           
          his death on May 4, 2001.                                                   
               e.  Noncompliance With Federal Income Tax Laws                         
               The record is devoid of any information regarding whether              
          petitioner has not made a good faith effort to comply with                  
          Federal income tax laws in the tax years following the tax years            
          to which the request for relief relates.                                    











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