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installment agreements for the payment of amounts reported on
delinquent Federal income tax returns, and the tax liabilities
for years prior to 1995 ultimately were satisfied through these
installment agreements or otherwise.
Petitioner’s 1995 joint Federal income tax return was filed
on March 21, 1997. Taking into account the Federal income tax
liability reported on the return and prepayment credits
consisting entirely of petitioner’s income tax withholdings, the
return shows a balance due of $3,751 that was not paid with the
return.2 At the time she signed the 1995 return, petitioner knew
that the tax liability reported on the return had not fully been
paid.
During the marriage, petitioner’s former spouse began to
abuse alcohol and drugs. During the final years of the marriage,
petitioner’s former spouse became abusive towards her, and at
times petitioner feared for her safety. In June 1997, the years
of substance abuse culminated in a violent episode that prompted
petitioner to call the police in order to have her former spouse
removed from the marital residence. The resultant police
report noted petitioner’s former spouse’s substance abuse and
2 The unpaid balance consists of the sec. 1401 self-
employment tax and sec. 1 income tax on the self-employment
income of petitioner’s former spouse.
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