- 35 - Attributable to Nonrequesting Spouse The respective liabilities for the taxable years 1994, 1995, 1998, and 1999 are self-employment tax liabilities that are solely attributable to Mr. Butner. This factor favors granting relief. Significant Benefit Respondent contends that petitioner received a significant benefit, beyond normal support, from the tax liabilities 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 secretarial wages. However, petitioner had no secre- tarial training and reported her occupation as “HOME- MAKER” on the joint returns which she and her husband filed for these years. * * * Respondent further contends that petitioner received a significant benefit by filing joint income tax returns with Mr. Butner for the respective taxable years at issue because she availed herself of the net operating loss carryovers arising from his business enterprises and thereby eliminated the income tax liabilities that would have been due from her had she filed separately. During the years at issue, Mr. Butner paid wages to peti- tioner for performing secretarial services. He paid her $2,600 in 1994, $11,060 in 1995, $16,952 in 1998, and $17,278 in 1999. During cross-examination, petitioner admitted that she had no secretarial training. During the years 1994, 1995, 1998, andPage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: November 10, 2007