- 18 - the proceeds on the sale of the Murrays’ house in mid-1997, and petitioner and intervenor filed for bankruptcy in September 1997. We disagree. Intervenor misled petitioner about his intentions to pay their taxes. Any knowledge about intervenor’s intent to pay his taxes that petitioner gleaned from her discovery of the tax liens on the Murrays’ house and their bankruptcy filing occurred after the Murrays filed the last of the returns for the years in issue in April 1997.7 e. Conclusion We conclude that this factor favors petitioner. 7. Whether the Underpayment of Tax Is Attributable to Intervenor Respondent concedes that the underpaid tax is solely attributable to intervenor. This factor favors petitioner. 8. Legal Obligation To Pay Tax The fact that the nonrequesting spouse has a legal obligation pursuant to a divorce decree or agreement to pay the outstanding liability favors granting relief. Rev. Proc. 2000- 15, sec. 4.03, 2000-1 C.B. at 448. In the property settlement signed in June 1998, intervenor agreed to pay community debts, which include the taxes from which petitioner seeks relief from liability. 7 The administrative record does not show that respondent took the proceeds on the sale of the Murray’s house in mid-1997 before the Murrays filed their 1996 tax return around Apr. 15, 1997.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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