- 23 - (F) Any other factor that the taxpayer claims bears on economic hardship and brings to the attention of the director. Petitioner has presented little or no evidence of her current financial situation, such as her current salary, her basic living expenses, or the amounts of her other debts. Nor has petitioner presented any evidence as to the nature and amount of her basic living expenses which she will be unable to pay if she is not granted her requested relief. On the record before us, we conclude that petitioner has failed to carry her burden of establishing within the context of section 301.6343-1(b)(4), Proced. & Admin. Regs., (1) her basic living expenses, and (2) that any expenses which she considers to be basic living expenses are “reasonable”. We also conclude that petitioner has failed to carry her burden of establishing that she would suffer an economic hardship if the Court were to deny her equitable relief and that she has failed to carry her burden of establishing that the economic hardship factor in Rev. Proc. 2000-15, sec. 4.03(1)(b), is present in this case. We conclude that this factor does not weigh in favor of granting equitable relief to petitioner for any of the subject years. Because Rev. Proc. 2000-15, supra, states that this factor will only serve to weigh in favor of granting relief when it is met, and fails to state that this factor will weigh against granting relief when it is not met, we consider this factor neutral.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011