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dependents, and the amount reasonably necessary for basic living
expenses.
Petitioner offered no evidence of her income, expenses,
assets, or liabilities other than her own testimony and that of
her spouse that they continued to live in the same house they
built in 1978, drove used cars, and took inexpensive vacations.
In the absence of corroborating evidence, we are not required to
accept petitioner’s self-serving testimony. Tokarski v.
Commissioner, 87 T.C. 74, 77 (1986). Consequently, we conclude
that petitioner has failed to carry her burden of proving that
requiring her to pay the liabilities from which she seeks relief
would result in economic hardship within the meaning of section
301.6343-1(b)(4), Proced. & Admin. Regs. Because petitioner has
failed to establish that she will suffer an economic hardship, we
conclude that this positive factor does not apply.
c. Abuse by Nonrequesting Spouse
Mr. Abelein never abused petitioner, and he did not persuade
petitioner to invest in the Hoyt partnerships by threatening to
abuse her. This positive factor does not apply. Ewing v.
Commissioner, supra at 46; Washington v. Commissioner, 120 T.C.
at 149.
d. No Knowledge or Reason To Know
The tax liabilities at issue in this case arose from
deficiencies. Petitioner argues that she did not know or have
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