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business, and so liability for those taxes is attributable to her
as well as to Supplee. This factor also weighs against relief.
Payment Responsibility: According to the divorce agreement,
Supplee is responsible for the payment of the disputed
liabilities. This is a factor weighing in her favor. The table
of conditions now looks like this:
Weighs for Relief Neutral Weighs against
Relief
Separated or
divorced
No abuse present
No significant
benefit
Lack of later
compliance with
Federal tax laws
Knowledge
No economic hardship
Liability
attributable to
petitioner
Non-requesting
spouse responsible
for paying tax under
divorce decree
Thus, Negoescu has only two factors weighing toward relief,
four weighing against relief, and two that are either neutral or
inconclusive. These factors are not all equally weighty--
Negoescu’s knowledge that the tax liabilities would not be paid,
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Last modified: May 25, 2011