E. Carolyn Mellen - Page 32




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            before us that petitioner has failed to persuade us that she                                
            would not be able to pay a reasonable amount for basic living                               
            expenses if she remained jointly and severally liable for peti-                             
            tioner’s unpaid liability for 1995.26  The record before us                                 
            establishes that petitioner, inter alia:  (1) Has been employed                             



                  25(...continued)                                                                      
            documentary evidence, we have found that she established such                               
            expenses.                                                                                   
                  26In attempting to persuade us that she would not be able to                          
            pay a reasonable amount for basic living expenses if she were not                           
            granted relief under sec. 6015(f), petitioner advances various                              
            contentions, all of which we find to be without merit.  To                                  
            illustrate, petitioner appears to contend that the $545 judgment                            
            obtained for an unpaid medical bill, which judgment remained                                
            unsatisfied as of the time of the trial herein, shows that she                              
            has been unable to pay a reasonable amount for basic living                                 
            expenses.  However, petitioner testified that the underlying                                
            medical bill with respect to which the $545 judgment in question                            
            was obtained “has been paid off.”  Petitioner apparently disputes                           
            the validity of the $545 judgment in question and therefore has                             
            refused to pay it.  On the record before us, we find that peti-                             
            tioner’s testimony does not establish that petitioner has been                              
            unable to pay the $545 judgment in question.                                                
                  By way of further illustration, petitioner contends on brief                          
            that petitioner’s “telephones had been disconnected for three                               
            (3) months”, the implication being that petitioner was not able                             
            to afford to pay her telephone bill.  To support her contention                             
            regarding her inability to pay her telephone bill for 3 months,                             
            petitioner relies on the notation “Disconnected called 11/9/00"                             
            that appeared in the margin of petitioner’s statement of dis-                               
            agreement with respect to respondent’s October 29, 1999 letter                              
            stating that she was not entitled to relief under sec. 6015(f).                             
            We reject the inference that petitioner attempts to draw from                               
            that notation.  The record establishes that the number shown in                             
            petitioner’s statement of disagreement was petitioner’s telephone                           
            number at Questar, and not her home telephone number.  Further-                             
            more, petitioner’s contention that “telephones had been discon-                             
            nected for three (3) months” is not supported by any evidence in                            
            the record.                                                                                 





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