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no longer has any credit cards. Petitioner’s reported assets
consisted of a 1999 model Kia Sophia,10 a “402B” account
established through her employer,11 and her home.
Petitioner purchased her home on February 1, 1999. As of
February 16, 2004, the value of the home was $111,500.
Petitioner purchased the home from her parents for $98,000. She
obtained a $78,000 mortgage and made a $20,000 downpayment, the
funds for which were given to her by her parents. She
subsequently refinanced her mortgage, and its balance as of
February 2004 was $101,000. Petitioner contends she did not use
the gift from her parents or the money she received from the
refinancing to pay the tax liabilities because “my ex-husband is
supposed to pay it. I’m not.”
Petitioner testified that her situation has changed since
2000 in that she no longer has credit card debt, has refinanced
her home, and is now caring for a blind uncle, but that her
situation is otherwise the same as when she filed the Form 433-A.
Petitioner contends it would be a hardship for her to pay the tax
liabilities because of her mortgage payments and the expense of
caring for her uncle. She did not introduce into evidence any
financial records regarding her current salary, basic living
10Petitioner reported that her Kia Sophia was worth $5,500
and that she had a $3,500 liability with respect to the car.
11The record is silent as to the value of the 402B account.
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