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Weighs for Relief Neutral Weighs against
Relief
Separated or Still married N/A
divorced
Abuse present No abuse present N/A
N/A No significant Significant benefit
benefit from the
deficiency or
underpayment
N/A Later compliance Lack of later
with Federal tax compliance with
laws Federal tax laws
No knowledge of N/A Knowledge
deficiency or
underpayment
Economic hardship if N/A No economic hardship
taxes had to be paid
Tax liability N/A Liability
attributable to non- attributable to
requesting spouse petitioner
Non-requesting No divorce decree Petitioner
spouse responsible responsible for
for paying tax under paying tax under
divorce decree divorce decree
The parties agree on two of the factors (those in italics),
and we now turn to the rest:
Abuse: Negoescu maintains that Supplee emotionally abused
her throughout the course of their marriage; however, she did not
offer any evidence in support of her argument other than her own
testimony. And we find that the Commissioner was not clearly
wrong in finding that her marital situation--though full of
heated arguments over money--did not sink to the level of abuse.
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Last modified: May 25, 2011