Sandrus L. Collier - Page 28




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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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