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(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.
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