Judge Adam B. (“Sport”) Landy is not put off by a multiplicity of factors. Innocent spousery has as many factors as anything else in the IRC. While neutrality is the general pigeonhole for most of them, most applicants can manage to grind out a couple in their favor.

Lisa Marie Walsh, T. C. Memo. 2025-91, filed 8/26/25, can come up with only one. And this even though her testimony was taken at the Tax Court trial, because Ms. Walsh is post-Section 6015(e)(7), where newly-discovered evidence means sworn testimony not taken at Appeals. See my blogpost “Comfortable Words,” 9/8/20.

But at the end, testimony doesn’t help.

“In summary, the only factor weighing in favor of relief for Ms. Walsh is that she is divorced. Ms. Walsh’s knowledge, the fact that she benefited from her and Mr. Walsh’s nonpayment of the tax liabilities, and her noncompliance with the federal income tax laws for the years following 2016 all weigh against relief. The remaining factors all are neutral. After weighing the above factors and examining the entire record before us, we conclude that Ms. Walsh failed to carry her burden and is not entitled to relief under section 6015(f) for 2014 through 2016.” T. C. Memo. 2025-91, at pp. 23-24.

Ms. Walsh knew her ex was trying to stiff their trusty attorney, who’d got them a good settlement for three (count ’em, three) years, getting $161K in deficiencies settled for $4105. A Taishoff “Good Job” to trusty attorney.