Suzanne E. Barrera, a.k.a. Suzanne E. Battle - Page 47




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          liabilities would not be paid at the respective times she signed            
          the 1998, 1999, and 2000 joint returns--especially because                  
          knowledge or reason to know that a tax would be unpaid is “an               
          extremely strong factor weighing against relief.”  Rev. Proc.               
          2000-15, sec. 4.03(2)(b), 2000-1 C.B. at 449.  We are also                  
          mindful of petitioner’s failure to demonstrate that she would               
          suffer economic hardship if relief were not granted, and that               
          the tax balances due for the years in issue are partly                      
          attributable to late filing and failure to pay additions to tax             
          and related interest and, for taxable year 2000, petitioner’s               
          $20,000 distribution from her IRA.                                          
               On the basis of the facts and circumstances presented, we              
          find that it would not be inequitable to hold petitioner liable             
          for the outstanding liabilities for taxable years 1998, 1999,               
          and 2000.  We, therefore, conclude that petitioner is not                   
          entitled to equitable relief from joint and several liability               
          under section 6015(f).  In reaching this conclusion, we have                
          considered all arguments made by the parties and, to the extent             
          not mentioned above, we conclude that they are irrelevant or                
          without merit.                                                              
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               








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