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were to make all these adjustments, total income would equal
approximately $10,345 per month leaving $1,673 per month
(approximately $20,007 per year) available to pay towards the
outstanding tax liability.
Petitioner did not present evidence that demonstrated that
petitioner will be unable to pay her reasonable basic living
expenses if relief is not granted. Sec. 301.6343-1(b)(4),
Proced. & Admin. Regs. Some of the expense figures provided on
the Form 433-A are unsupported and seem excessive. Accordingly,
we conclude that respondent was correct, and did not abuse his
discretion, in determining that petitioner would not suffer
economic hardship.
2. Additional Facts and Circumstances
Petitioner claims that Mr. Bartak played the dominant role
in handling the financial affairs of their family and she did not
have a choice not to sign the Hoyt documents or her tax returns.
Petitioner testified that Mr. Bartak “usually” handled the
family’s investments and that he would come to her about an
investment after he investigated it and thought they should
invest. Petitioner may have left the final decision to invest in
the Hoyt partnerships to Mr. Bartak; however, petitioner
acquiesced or agreed to go along with Mr. Bartak’s wishes.
Petitioner also claims that she did not want to sign the
Hoyt partnership documents or her returns. Petitioner, however,
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