- 45 - 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 reportedPage: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 NextLast modified: November 10, 2007