- 26 -
On the record before us, we find that Ms. Collier has failed
to carry her burden of establishing that with respect to each of
the years at issue the knowledge or reason to know element set
forth in section 4.02(1)(b) of Revenue Procedure 2000-15 is
present here.
With respect to the economic hardship element set forth in
section 4.02(1)(c) of Revenue Procedure 2000-15, Ms. Collier
contends that that element is present here. According to Ms.
Collier, if she were to pay the unpaid assessment for each of the
years at issue, she would suffer economic hardship. That is
because she claims that she has significant financial obligations
consisting of paying for her adult son’s college education, her
own postgraduate work, and the care of her mother.19
In determining whether a requesting spouse will suffer
economic hardship, section 4.02(1)(c) of Revenue Procedure 2000-
15 requires reliance on rules similar to those provided in
section 301.6343-1(b)(4), Proced. & Admin. Regs. Section
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.
Section 301.6343-1(b)(4), Proced. & Admin. Regs., provides:
(ii) Information from taxpayer. In determining a
reasonable amount for basic living expenses the direc-
19Ms. Collier also points out that she is not receiving
spousal support or alimony from Mr. Collier.
Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 NextLast modified: May 25, 2011