- 41 - 2002, almost 8 months after it was due; and (4) she paid the tax she owed for 2002 on October 19, 2003, about 6 months after it was due. We agree with respondent that petitioner failed to make a good faith effort to comply with income tax laws for tax years following the tax years in issue, 1991 through 1999. See Castle v. Commissioner, T.C. Memo. 2002-142 (requesting spouse failed to establish compliance factor did not apply against her where she provided no explanation for filing return for subsequent tax year more than 1 year late); cf. Ewing v. Commissioner, 122 T.C. at 46-47. This factor weighs against granting petitioner relief. 7. Attribution Factor for 1999 As previously discussed, respondent acknowledges that the attribution factor weighs in favor of granting petitioner relief for 1991 through 1998. Section 4.03(1)(f) of Rev. Proc. 2000-15, 2000-1 C.B. at 448-449, provides that the fact that the liability for which relief is sought is solely attributable to the nonrequesting spouse weighs in favor of relief. Section 4.03(2)(a) of Rev. Proc. 2000-15, 2000-1 C.B. at 449, provides that the fact that the unpaid liability is attributable to the requesting spouse weighs against granting relief. Respondent contends that the attribution factor does not weigh in favor ofPage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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