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were proper. On the basis of these facts, we conclude that the
underpayments of tax are attributable solely to Mr. Scott.
7. Significant Benefit
During their marriage, including the years at issue, the
Scotts did not live well, and money was tight. They had modest
furnishings and vehicles, and they never owned a home.
Petitioner did not benefit beyond normal support from the unpaid
liabilities for all of the years at issue. Therefore, this
factor favors granting petitioner relief. See Van Arsdalen v.
Commissioner, T.C. Memo. 2007-48.
8. Noncompliance With Federal Income Tax Laws
The fact that the requesting spouse has not made a good
faith effort to comply with Federal income tax laws in years
after the years for which relief is sought is a factor that
weighs against granting relief. Petitioner and Mr. Smith filed a
joint Federal income tax return for 2002 that reported an
overpayment of tax. Initially, respondent determined that the
return contained an error and that the Smiths underpaid their
2002 tax. The issue was ultimately resolved, and on June 16,
2003, respondent sent them a refund of $717.74. Petitioner
complied with Federal income tax laws. This factor is neutral.
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