Connie J. Meadows - Page 10

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        return.  Petitioner testified that even though Mr. Meadows assured            
        her that he would properly manage their tax obligations, she was              
        aware that she could not trust him to actually do so.  Moreover,              
        petitioner testified that Mr. Meadows had always prepared and                 
        filed her tax returns, both the joint and separate returns, and               
        that several years before 1999, respondent had garnished her                  
        wages.                                                                        
             Nothing in petitioner’s testimony establishes that petitioner            
        believed that Mr. Meadows would pay the reported tax liability.               
        Even if we could find (which we do not) that petitioner believed              
        that Mr. Meadows would pay the reported tax liability, we could               
        not find that her belief was reasonable.  On the contrary,                    
        petitioner’s experience in relying on Mr. Meadows to pay income               
        taxes had resulted in the garnishing of her wages.                            
             Further, we do not find that petitioner will suffer economic             
        hardship if she is not granted innocent spouse relief.  The record            
        shows that petitioner earned more than $46,000 in 2005.  The                  
        unpaid tax that respondent seeks to recover, including interest as            
        of the date of trial, is approximately $2,300.  Petitioner did not            
        provide any supporting documentation, but she testified that she              
        contributes to the support of her young adult children and her                
        elderly parents.  Even if we were persuaded that petitioner’s                 
        living expenses include the cost of supporting adult children and             
        elderly parents, these costs were not quantified, and we cannot               






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