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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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