- 20 - relief from joint liability herein. We note particularly that no financial records as to petitioner’s net worth were placed in evidence. Conclusion Taking into account all of the facts and circumstances before us in this case and balancing the above relevant guidelines and factors, we conclude that it would be inequitable to hold petitioner liable for the balances due relating to petitioner and Alimam’s 1993, 1994, and 1995 joint Federal income tax liabilities and that are attributable to Alimam. We note particularly the following: Alimam’s legal obligation relating to the unpaid taxes, the fact that the taxes in issue are attributable to Alimam’s income, Alimam’s deception with regard to his investments and nonpayment of the taxes due, the absence of any significant benefit to petitioner from Alimam’s failure to pay the taxes, Alimam’s exclusion of petitioner from the tax return preparation process and from his financial affairs, petitioner’s payment of the majority of the family’s expenses and her continued support of the children, and petitioner’s payment every year of the Federal income taxes attributable to her income. On the facts of this case, under section 6015(f), petitioner is entitled to equitable relief from joint and several liability with respect to the unpaid taxes at issue herein.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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