Rosalinda E. Alt - Page 16




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               We have also considered other factors that are relevant to               
          whether it would be inequitable to hold petitioner liable.  We                
          find that petitioner will not experience economic hardship if                 
          relief from the liabilities is not granted given her current                  
          level of income.8  See Von Kalinowski v. Commissioner, T.C. Memo.             
          2001-21; Walters v. Commissioner, T.C. Memo. 1998-111; Dillon v.              
          Commissioner, T.C. Memo. 1998-5.  Petitioner did not present                  
          evidence that demonstrated that she will be unable to pay her                 
          reasonable basic living expenses if relief is not granted.  Sec.              
          301.6343-1(b)(4), Proced. & Admin. Regs.                                      
               We also may consider whether the requesting spouse was                   
          deserted, divorced, or separated.  See Walters v. Commissioner,               
          supra.  Petitioner and Dr. Alt remain married.  The two have not              
          separated, and petitioner has not been left by her husband to                 
          deal with the tax liabilities alone.  Instead, petitioner                     
          continues to enjoy the lifestyle and financial security that are              
          largely attributable to her husband’s assets and income.  On the              
          basis of the facts and circumstances, we hold that it would not               
          be inequitable to hold petitioner liable for the deficiencies in              
          tax for taxable years 1982 to 1988.  We, therefore, conclude that             
          petitioner is not entitled to relief under section 6015(b).                   




               8  Petitioner and Dr. Alt’s combined annual income was over              
          $150,000 in 2000, see supra p. 8.                                             





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