Although the Severances failed to timely file joint federal income tax returns for certain years, to wit, the 2014-16 taxable years, these returns were filed before petitioner's Form 8857 was received by the IRS on March 18, 2019, and the record seems to be silent as to the Severances' level of compliance with the income tax laws after the IRS's receipt of petitioner's Form 8857.15 We will treat this factor as neutral. Please summarize