Ruth E. Neal - Page 13

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               Petitioner did not significantly benefit from Alimam’s                   
          failure to pay the tax balances shown to be due on their joint                
          Federal income tax returns.                                                   
               For 1996 and subsequent years, petitioner has continued to               
          have income taxes withheld from her salary, has timely filed her              
          separate individual Federal income tax returns, and has paid in               
          full her Federal income tax liabilities.                                      
               Petitioner continues to support her three children                       
          financially, two of whom are adults and not currently attending               
          school.  On account of the bankruptcies, unpaid tax liabilities,              
          resulting poor credit, and other financial problems arising from              
          her marriage to Alimam, petitioner currently resides in a home                
          and drives a car owned by friends.  Since her divorce from                    
          Alimam, petitioner has not taken vacations, either with the                   
          children or separately.                                                       

                                        OPINION                                         
               Generally, taxpayers filing joint Federal income tax returns             
          are jointly and severally liable for all taxes due thereon.  Sec.             
          6013(d)(3).                                                                   
               Taxpayers, however, may be relieved of joint and several                 
          liability under limited circumstances described in section                    
          6015(b), (c), and (f).  Petitioner alleges that, on the                       
          particular facts and circumstances of this case, respondent                   







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