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their 1996 return prior to their meeting with their return
preparer. Petitioner knew that $5,072 of intervenor’s earnings
were not reported on their 1996 return. Petitioner, along with
intervenor, benefited from the unreported income by receiving a
larger tax refund in 1996. There was also no legal obligation
pursuant to the divorce decree or other agreement for intervenor
to pay the outstanding joint tax liability.
Finally, petitioner has also failed to establish that he
will suffer economic hardship if equitable relief is not granted.
In determining whether a requesting spouse will suffer economic
hardship, the revenue procedure refers to rules similar to those
provided in section 301.6343-1(b)(4), Proced. & Admin. Regs.
That regulation generally provides that an individual suffers an
economic hardship if the individual is unable to pay his or her
reasonable basic living expenses. See id.
Petitioner relies solely on the fact that he is a single
father who receives no child support. However, petitioner is
currently employed and earns an annual base salary of $40,456.
Petitioner also receives monthly disability payments of $749.
Petitioner has provided no information as to his monthly
expenses. Petitioner likewise did not provide respondent with
any evidence of financial hardship during respondent’s decision-
making process. Thus, petitioner has failed to show that he will
suffer any economic hardship if equitable relief is denied.
Based on the facts and circumstances presented in this case,
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