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1993 liability. In support of that contention, petitioner
asserts that (1) “she [petitioner] has no assets which can be
liquidated to pay this debt” and that (2) at the time of the
trial in this case, she expected to be “furloughed from the
airline [Continental Airlines]” in about 1 week.
Petitioner did not proffer any evidence to establish that,
if she were to pay the unpaid 1993 liability, she would not be
able to pay a reasonable amount for her basic living expenses.
Indeed, except for petitioner’s testimony that she expected to be
“furloughed” from her position with Continental Airlines shortly
after the trial in this case, petitioner did not proffer any
evidence relating to the factors that section 301.6343-1(b)(4),
Proced. & Admin. Regs., indicates are to be considered in deter-
mining a reasonable amount for basic living expenses.9 We are
unwilling to rely on petitioner’s self-serving and conclusory
testimony to support her contention that she would suffer eco-
nomic hardship if she were not granted relief under section
6015(f). On the record before us, we find that petitioner has
failed to carry her burden of establishing that the economic
hardship element is present in this case.
9At trial, petitioner testified that she has a son who was a
minor during at least some part of petitioner’s marriage to Mr.
Castle. Petitioner proffered no evidence to establish at rele-
vant times her son’s age, whether he was her dependent, and the
amount that she spent with respect to him for basic living
expenses.
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