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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.
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