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vi. Requesting Spouse’s Legal Obligation
The Merendinos were married during all relevant times and
remain so. In addition, neither petitioner nor Dr. Merendino had
legally assumed sole responsibility to pay unpaid tax liability
at issue. Therefore, this factor is not present in this case and
is a neutral factor.
III. Conclusion
The testimony in this case is not informative as to what
actually led petitioner to sign the joint return for the tax year
1996 in December 1998. Understanding the motivation for that
decision would have been preferable to petitioner’s mistaken
attempt to assert that she never actually signed the return. We
cannot speculate as to how petitioner was led to sign the return,
and she has not accurately explained why she did. We find as
fact that she signed the return, and we conclude that petitioner
has failed to carry her burden of showing that respondent abused
his discretion in denying petitioner equitable relief under
section 6015(f) with respect to the unpaid 1996 tax liability.
To reflect the foregoing,
Decision will be entered
for respondent.
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