Teresa G. Butner - Page 29




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          taxable years 1994, 1995, 1998, and 1999 of $330, $238, $1,466,             
          and $1,189, if she had not filed such joint returns and availed             
          herself of the net operating loss carryovers associated with Mr.            
          Butner's business enterprises; (3) petitioner also received a               
          significant benefit "beyond normal support, from the tax liabili-           
          ties that went unpaid in that money which her husband could have            
          used to pay estimated taxes to reduce or satisfy his                        
          self-employment tax liability was paid to petitioner as secre-              
          tarial wages”; (4) petitioner would not suffer economic hardship            
          if the Court were not to grant relief from the liability for each           
          of the taxable years at issue; (5) petitioner knew or had reason            
          to know when she signed and filed each of the joint income tax              
          returns in question that the liability reported in each such                
          return would not be paid due to her knowledge of previous judg-             
          ments and assessments against Mr. Butner and herself; and (6)               
          petitioner failed to comply with the income tax laws for the                
          taxable years following the taxable years for which relief is               
          sought.  According to respondent, the foregoing factors weigh               
          against granting relief under section 6015(f) to petitioner.                
               We now address the application of each of the factors set              
          forth in Revenue Procedure 2000-15 that weigh in favor of or                
          against granting petitioner relief under section 6015(f).                   
          Marital Status                                                              
               Respondent contends that this factor is neutral.  We agree.            







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