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A that during 1998 she and Mr. Simon had separate, not joint,
bank accounts, that she did not review Mr. Simon’s checkbook or
bank statements, that she did not open mail addressed to Mr.
Simon, that she made payments for her automobile, her clothing,
and certain unidentified food and furniture, and that Mr. Simon
made payments for the mortgage, utilities, insurance, and his
clothing.
In response to a question relating to whether petitioner’s
payment of the tax liability for taxable year 1998 (unpaid 1998
liability) would cause an economic hardship to her, petitioner
indicated that it would not. However, petitioner added that “it
would be grossly unfair because I received no economic benefit--
in fact, I was not aware he withdrew these [retirement] funds”.
In response to a question asking for any other information
in support of petitioner’s position that she is entitled to
relief under section 6015 with respect to taxable year 1998,
petitioner stated:
I have remarried since my divorce [from Mr. Simon], and
this is my reason for saying * * * that if I had to
pay, it would not create an economic hardship, although
it would be quite difficult for me. Inasmuch as my
former husband used the money [the retirement distribu-
tion] entirely for himself, and kept me totally unaware
of its existence, I feel it is only fair that he should
accept the responsibility for paying the tax liability
he incurred.
In petitioner’s Form 886-A, petitioner did not claim that
Mr. Simon abused her during their marriage.
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