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evidence as to the amounts of such claimed expenses. On the
instant record, we find that Ms. Collier has failed to carry her
burden of showing that the amounts of such expenses, when added
to the amounts of her other expenses that qualify as basic living
expenses within the meaning of that regulation, are reasonable.21
On the record before us, we find that Ms. Collier has failed
to carry her burden of establishing that respondent’s determina-
tion to deny her relief, in whole or in part, for each of the
years at issue will cause her to be unable to pay a reasonable
amount for basic living expenses within the meaning of section
301.6343-1(b)(4), Proced. & Admin. Regs. On that record, we find
that Ms. Collier has failed to carry her burden of establishing
that with respect to each of the years at issue the economic
hardship element set forth in section 4.02(1)(c) of Revenue
Procedure 2000-15 is present in the instant case.
On the record before us, we find that Ms. Collier has failed
to carry her burden of establishing that with respect to each of
20(...continued)
discussed below, Ms. Collier has failed to establish the amounts
that she spends for, inter alia, food, clothing, housing, and
medical care for her mother.
21As for Ms. Collier’s contention that she does not receive
spousal support or alimony from Mr. Collier, the record estab-
lishes Ms. Collier’s ability to earn a living. At the time of
the trial in this case, Ms. Collier was earning approximately
$60,000 a year. We also note that Ms. Collier appears to have a
right of indemnification against Mr. Collier for the payment of
certain tax liabilities under their separation agreement and
judgment of divorce.
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