Ruth E. Neal - Page 17

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          (1) Under the divorce decree, Alimam has a legal obligation to                
          pay the unpaid taxes due for the years petitioner and Alimam were             
          married, including 1993, 1994, and 1995; (2) essentially all of               
          the underpayments at issue herein are attributable to Alimam;                 
          (3) petitioner and Alimam are currently divorced; (4) petitioner              
          did not receive a significant benefit from the unpaid taxes; and              
          (5) petitioner has, throughout her marriage with Alimam and for               
          subsequent years, made a good faith effort to comply with the tax             
          laws with regard to her income.                                               
               The two remaining factors (whether petitioner had knowledge              
          of or reason to know of Alimam’s nonpayment of the taxes due and              
          whether petitioner would suffer economic hardship if not granted              
          relief from joint and several liability) are more difficult                   
          questions.                                                                    

          Petitioner’s Knowledge of or Reason To Know                                   
          of the Nonpayment of the Tax                                                  
               In determining whether petitioner, at the time the tax                   
          returns were signed, had knowledge or reason to know that the tax             
          reported on the returns would not be paid, relevant factors                   
          include petitioner’s level of education, petitioner’s involvement             
          in the family’s financial affairs, petitioner’s lifestyle,                    
          standard of living, and spending patterns, and Alimam’s                       
          evasiveness and deceit concerning the marital finances.  See Levy             
          v. Commissioner, T.C. Memo. 2005-92 (citing Kistner v.                        






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