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Petitioner’s claim of abuse is self-serving, and she points
to no specific incidents or threats at or near the time she
signed the return. See In re Hinckley, 256 Bankr. 814 (Bankr.
M.D. Fla. 2000) (stating that abuse at that time is a significant
factor); see also Collier v. Commissioner, T.C. Memo. 2002-144
(stating that the Court would not rely on the lay witness’s
opinion regarding the taxpayer’s alleged verbal and mental abuse
because the Court found it to be conclusory and lacking in
specificity as to the facts). Putting aside the “name calling”
and other remarks, petitioner’s allegations of abuse involve
periods after she signed the return and, therefore, do not weigh
in favor of relief. See, e.g., Krasner v. Commissioner, T.C.
Memo. 2006-31 (stating that the police reports submitted to
verify the taxpayer’s claim of abuse were unsupportive because
they dated to a period after the taxpayer signed the return).
The Court does not find that the “name calling” and other remarks
were of such magnitude as to warrant weighing in favor of relief.
See Ogonoski v. Commissioner, T.C. Memo. 2004-52 (stating that
the abuse factor is neutral where there is no evidence of
physical or mental abuse “in any sense to which the tax law or
common experience will accord any recognition”).
Finally, there is nothing in the record, other than
petitioner’s self-serving statements, that corroborates the
alleged abuse. See Baumann v. Commissioner, T.C. Memo. 2005-31
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