Wendy L. Chadwick - Page 23

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         Rev. Proc. 2000-15, sec. 4.03(2)(f).  In the present case where              
         the divorce decree holds each party equally responsible for all              
         Federal income tax liabilities of the parties from the date of               
         marriage through December 31, 1998, this factor is considered                
         neutral.                                                                     
         6.   Attributable to Nonrequesting Spouse                                    
              As previously stated, the majority of the income tax                    
         liability for taxable year 1995 was a result of petitioner’s wage            
         income.  However, the income tax liabilities of $1,509.92 and                
         $822.64 for taxable years 1997 and 1998, respectively, are                   
         attributable to Mr. Tillotson’s self employment and his failure              
         to pay any estimated taxes.  As to the income tax liabilities of             
         $1,509.92 and $822.64 for taxable years 1997 and 1998,                       
         respectively, this factor favors granting petitioner equitable               
         relief.                                                                      
         7.  Significant Benefit                                                      
              Respondent contends that petitioner received benefits from              
         the proceeds of Mr. Tillotson’s self-employment in the form of               
         payment of joint household expenses and living expenses.                     
              Petitioner testified at trial that Mr. Tillotson would pay              
         household and living expenses with both his paychecks and her                
         paychecks.  Petitioner also testified at trial that Mr. Tillotson            
         was responsible for paying the bills.  Rev. Proc. 2000-15, sec.              
         4.03(2)(c), states that “The requesting spouse has significantly             






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