Ruth E. Neal - Page 20

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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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