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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, and
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