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she and Mr. Capehart had approximately $2,000 in the bank, drove
older automobiles, and maintained an average standard of living.
Petitioner’s failure to offer credible evidence of her current
salary, her basic living expenses, her current debts, and all of
her current assets makes it impossible for us to evaluate her
ability to pay the liabilities allocated to her under section
6015(c). Moreover, petitioner did not prove that requiring her
to pay the reduced liabilities resulting from the allocation of
liability under section 6015(c) would result in economic
hardship. We conclude, therefore, that petitioner has failed to
carry her burden of proving that requiring her to pay the reduced
liabilities would result in an 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
Petitioner alleges that she was motivated to participate in
the investment because she feared Mr. Capehart. For purposes of
this analysis, we shall treat petitioner’s allegation as an
allegation that petitioner was abused by Mr. Capehart, and we
reject it. The record simply does not support a finding that Mr.
Capehart persuaded petitioner to invest in the Hoyt partnerships
by threatening or abusing her. Among other things, we note that
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