Connie A. Washington - Page 20

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          asserts that petitioner provided no documentation to demonstrate an         
          economic hardship.   We disagree.                                           
               Petitioner received no assets upon the dissolution of her              
          marriage.  She does not own a house, does not take any vacations,           
          and although she possesses an automobile, she does not own it.  The         
          IRS lien for the tax liability harms petitioner’s credit rating and         
          limits her ability to obtain a loan.                                        
               Petitioner receives no spousal or child support from her               
          former husband.  To the contrary, she is the sole provider for her          
          two children.  Petitioner’s wages are her only source of income and         
          provide a near poverty level existence for her and her two                  
          children.7  Respondent’s levy against petitioner’s wages, had it            
          not been released, would have resulted  in  her  receiving                  
          approximately $240 biweekly to support herself and her two                  
          children.  A monthly income of $480 is substantially below the              
          poverty level for a family of three and is insufficient to pay rent         
          and other basic living expenses for petitioner and her two                  
          children.                                                                   
               Based on the record before us and petitioner’s credible                
          testimony, we are persuaded that petitioner will suffer great               
          economic hardship if she is not relieved of the liability.                  


               7    The 2002 Poverty Guidelines for the 48 Contiguous States          
          and the District of Columbia for a family of three is $15,020. U.S.         
          Dept. of Health and Human Services, The 2002 HHS Poverty                    
          Guidelines, 67 Fed. Reg. 6931 (Feb. 14, 2002).                              




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