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6. Attribution--The unpaid liability arises primarily
if not solely from income attributable to Paul. This
factor weighs in favor of relief.
Factors Weighing Against Relief
1. Attribution--The unpaid liability arises primarily
if not solely from income attributable to Paul. This
factor does not weigh against relief.
2. Knowledge or reason to know--Janet is college
educated. She signed the return, which shows a balance
due. Even a cursory review of the return would have
alerted Janet to the fact that there was a balance due.
She has not presented any evidence to show that she had
a reasonable belief that Paul was going to pay the
balance due. In view of these facts, this factor
weighs very strongly against relief.
3. Significant benefit--As a member of the household
Janet received benefit from the unpaid taxes. There-
fore, this factor weighs against relief.
4. Lack of economic hardship--Janet has not shown
that she would experience an economic hardship if
relief is not granted. This factor weighs against
relief.
5. Noncompliance with federal tax laws--It appears
that Janet has complied with all federal income tax
laws in subsequent years. Accordingly, this factor
does not weight against relief.
6. Requesting spouse’s legal obligation--There is no
legal agreement or agreement between the spouses that
provides that Janet has an obligation to pay the amount
owed. Accordingly, this factor does not weigh against
relief.
MY EVALUATION
After consideration of all the arguments, facts and
circumstances, it is my reasoned judgment that Janet
Krasner has not demonstrated that it would be inequita-
ble to hold her liable for the joint 1998 tax liabil-
ity.
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