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B. Negative Factors
i. Attributable to the Requesting Spouse
The majority of the liability is attributable to Dr.
Merendino. Petitioner seeks relief only from the unpaid tax
liability for that portion of the liability attributable to Dr.
Merendino. Therefore, this factor is neutral.
ii. Knowledge or Reason to Know
We have concluded above that petitioner should have known
the unpaid tax liability would not be paid. Thus, this factor
weighs against granting petitioner equitable relief. Rev. Proc.
2000-15, sec. 4.03(2)(b), 2000-1 C.B. 447, 448-449.
iii. Significant Benefit
Respondent concedes that petitioner did not significantly
benefit from the tax savings.
iv. Lack of Economic Hardship
As we noted and have found in our analysis previously
discussed, petitioner has failed to carry her burden of proving
that she will suffer economic hardship if relief is denied.
Consequently, this factor weighs against granting petitioner
equitable relief.
v. Noncompliance With Federal Income Tax Laws in
Subsequent Years
Respondent did not determine that this factor is present in
the instant case, and thus this is a neutral factor. See Ewing
v. Commissioner, 122 T.C. at 46-47.
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