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view this factor in favor of petitioner.
ii. Economic Hardship
Our analysis under Rev. Proc. 2000-15, sec. 4.02, concluding
that petitioner does not satisfy the economic hardship factor
remains applicable here and weighs against petitioner.
iii. Abuse by Nonrequesting Spouse
There is no evidence in the record that Dr. Merendino abused
petitioner. Thus, this is a neutral factor. Ewing v.
Commissioner, 122 T.C. at 46; Washington v. Commissioner, 120
T.C. at 149; Rev. Proc. 2000-15, sec. 4.03(1)(c).
iv. No Knowledge or Reason To Know
As addressed previously, we are not persuaded that
petitioner lacked knowledge or reason to know that any unpaid tax
liability for 1996 would not be paid. Thus, we find petitioner
has failed to carry her burden, and this factor weighs against
petitioner.
v. Nonrequesting Spouse's Legal Obligation
Because petitioner is not separated or divorced from Dr.
Merendino, this is a neutral factor.
vi. Liabilities Solely Attributable to
Nonrequesting Spouse
Petitioner seeks relief from paying the amount of tax
liability that is attributable to Dr. Merendino. Petitioner
agrees to pay the tax liability attributable to her income.
Therefore, this factor weighs in favor of petitioner.
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