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Hence, petitioner’s compliance with tax laws subsequent to
the filing of the 1999 return reveals shortcomings.
Additionally, petitioner’s generalized allusions to financial
pressures and information misplaced during moves are insufficient
to establish good faith efforts with respect to the series of
delinquencies occurring over a period of years. This factor
weighs against relief.
The presence of abuse is a factor weighing in favor of
relief, but its absence carries no contrary weight. Rev. Proc.
2003-61, sec. 4.03(2)(b)(i), 2003-2 C.B. at 299. Because
petitioner has at no point alleged any abuse by Dr. Banderas,
this factor is neutral.
The final factor enumerated in the revenue procedure, and
again weighing only in favor of and not against relief, is
directed toward whether the requesting spouse was in poor mental
or physical health when signing the return or seeking relief.
Id. sec. 4.03(2)(b)(ii), 2003-2 C.B. at 299. The nature, extent,
and duration of illness are to be taken into account. Id.
Petitioner’s statements at trial and on brief incorporate general
assertions of high blood pressure, depression, and bad knees.
Nonetheless, the record is bereft of any corroborating medical
documentation or any specific contentions regarding how such
ailments might have impacted petitioner’s ability to meet her
Federal tax obligations. In fact, petitioner acknowledged that,
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