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and 1999, but it does not weigh in favor of relief for taxable
year 2000.
7. Significant Benefit
The record shows that the funds from the unpaid liabilities
were used by Mr. Barrera to pay his family’s household and
living expenses during taxable years 1998, 1999, and 2000. We
thus find that petitioner did not significantly benefit “beyond
normal support” from the unpaid liabilities for taxable years
1998, 1999, and 2000. This factor is neutral.
8. Noncompliance With Federal Income Tax Laws
Petitioner has complied with Federal income tax laws for
the years following taxable year 2000, the last year in issue.
This factor is neutral.
Conclusion
A factor favoring relief for all three of the years in
issue is that petitioner and Mr. Barrera are separated and
petitioner is seeking dissolution of their marriage. Also
somewhat favoring relief, at least for taxable years 1998 and
1999, is that the underpayments are attributable to income
earned by Mr. Barrera, though we note that petitioner, who had
no or minimal income during these years, enjoyed the use of Mr.
Barrera’s income.
The factors favoring relief are strongly outweighed by
petitioner’s knowledge or reason to know that the reported
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