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On the record before us, we find that petitioner has failed to
carry her burden of establishing that the knowledge or reason to
know element is present in the instant case.
With respect to the economic hardship element,8 petitioner
contends that that element is present in this case because,
“Currently, Ms. Castle is not in a position to pay” the unpaid
8In determining whether a requesting spouse will suffer
economic hardship, sec. 4.02(1)(c) of Revenue Procedure 2000-15
requires reliance on rules similar to those provided in sec.
301.6343-1(b)(4), Proced. & Admin. Regs. Sec. 301.6343-
1(b)(4)(i), Proced. & Admin. Regs., generally provides that an
individual suffers an economic hardship if the individual is
unable to pay his or her reasonable basic living expenses. Sec.
301.6343-1(b)(4)(ii), Proced. & Admin. Regs., provides in perti-
nent part:
(ii) Information from taxpayer. In determining a
reasonable amount for basic living expenses the direc-
tor will consider any information provided by the
taxpayer including--
(A) The taxpayer’s age, employment status and
history, ability to earn, number of dependents, * * *;
(B) The amount reasonably necessary for food,
clothing, housing * * *, medical expenses * * *, trans-
portation, current tax payments * * *;
(C) The cost of living in the geographic area
in which the taxpayer resides;
(D) The amount of property exempt from levy
which is available to pay the taxpayer’s expenses;
(E) Any extraordinary circumstances such as
special education expenses, a medical catastrophe, or
natural disaster; and
(F) Any other factor that the taxpayer claims
bears on economic hardship and brings to the attention
of the director.
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