Tracie Young - Page 21

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         7.  Significant Benefit                                                      
              Respondent contends that petitioner received benefits from              
         the proceeds of Mr. Glaze’s wage income received from Mayflower              
         in the form of payment of joint household expenses.                          
              Petitioner admitted at trial that she and Mr. Glaze were                
         personally liable for the household expenses which were paid by              
         the moneys received by Mr. Glaze as wage income from Mayflower.              
         Petitioner also testified at trial that during 1995 she received             
         gifts from Mr. Glaze, one of which was $500 that she used as a               
         downpayment for the purchase of a 1984 Toyota Corolla.                       
         Therefore, we find that petitioner did benefit from the                      
         unreported wage income received by Mr. Glaze from Mayflower.                 
         8.  Noncompliance With Federal Income Tax Laws                               
              There is no evidence in the record as to this factor.                   
         Therefore, we consider this factor neutral.                                  
         9.  Conclusion                                                               
              The factors that weigh against granting relief to petitioner            
         outweigh those factors favoring relief.  Therefore, under these              
         facts and circumstances, we hold that respondent did not abuse               
         his discretion in denying equitable relief to petitioner under               
         section 6015(f).                                                             

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