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The Court finds, however, that petitioner has not met her
burden. Petitioner did not introduce into evidence her financial
records; i.e., current salary, living expenses, and amounts of
other debts, which are necessary to support her claim that she
will be unable to pay reasonable, basic living expenses if relief
is not granted. Substantiation was particularly necessary in
view of petitioner’s assertion that her expenses exceeded her
income as well as the large amount of expenses claimed (i.e.,
$1,025 for food and $600 for utilities). Moreover, petitioner
remains gainfully employed and has only one child whom she “helps
attend school.” Therefore, this factor weighs against relief.
See Banderas v. Commissioner, supra (stating that lack of
economic hardship weighs against relief under Rev. Proc. 2003-
61); cf. Butner v. Commissioner, supra (stating same under Rev.
Proc. 2000-15).
Knowledge or Reason To Know: A Properly Reported but Not Paid
Liability
The IRS will also consider whether the requesting spouse did
not know or had no reason to know that the nonelecting spouse
would not pay the liability. Rev. Proc. 2003-61, sec.
4.03(2)(a)(iii)(A), 2003-2 C.B. at 298. In the case of a
properly reported but unpaid liability, the relevant knowledge is
whether the taxpayer knew or had reason to know when the return
was signed that the tax would not be paid. See Washington v.
Commissioner, 120 T.C. at 151; see also Feldman v. Commissioner,
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