Wendy L. Chadwick - Page 19

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              During the appeals process, petitioner reported that her                
         monthly income was $1,352.59, and she reported that her monthly              
         expenses totaled $1,220.                                                     
              It appears from the record that petitioner earns sufficient             
         income such that she would not experience economic hardship if               
         required to pay some or all of the tax deficiencies at issue in              
         the present case.  Petitioner has not presented any documentation            
         or testimony to contradict the above claims or the determination             
         of respondent; therefore, we find that petitioner will not suffer            
         economic hardship if relief is not granted.  This factor favors              
         denying relief.                                                              
         3.  Abuse                                                                    
              At trial, petitioner testified that she was physically and              
         verbally abused by Mr. Tillotson during their marriage.                      
         Petitioner did not present any documentation to substantiate such            
         a claim, other than her testimony.  However, we find petitioner’s            
         testimony, on this issue, to be credible and find that petitioner            
         was abused by Mr. Tillotson during their marriage.  Spousal abuse            
         is a factor listed in Rev. Proc. 2000-15, sec. 4.03(1), that will            
         weigh in favor of equitable relief, if found, but will not weigh             
         against equitable relief if not present in a case.  Therefore,               
         this factor favors granting relief.                                          









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