- 32 - 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.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
Last modified: May 25, 2011