- 32 - 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,Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011