Sandrus L. Collier - Page 26

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               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.                                

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