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granted. Petitioner earns approximately $52,000 a year, and
rents a comfortable home. Petitioner and John’s $17,516
underpayment has already been paid in full, and thus no further
payments will be required from petitioner if relief is not
granted.
We note, however, that petitioner did pay significant other
debts attributable to John and to his business. Petitioner also
has had to rebuild her credit due to John’s conduct. For 6 years
petitioner worked for John without being paid. John squandered
most of the marital assets, including the equity in the Castle
Rock home, leaving little for petitioner after the divorce.
These additional factors mitigate the weight to be given the
economic hardship factor.
(2) Knowledge or Reason To Know
It appears that petitioner should have been on notice that
the $17,516 underpayment might not be paid. Enclosed with the
tax return was a letter from petitioner and John stating that
full payment could not be made with the return. In previous
years, petitioner and John had had difficulty paying their
Federal income taxes. These facts combined with John’s
continuing business and financial difficulties should have put
petitioner on notice that the $17,516 underpayment reflected on
the 1995 joint Federal income tax return might not be paid in
full.
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