- 28 - 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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