Verna Doyel - Page 30

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          relief from the liabilities is not granted given her current                
          level of income.  See Alt v. Commissioner, supra at 314-315; Von            
          Kalinowski v. Commissioner, T.C. Memo. 2001-21; Walters v.                  
          Commissioner, T.C. Memo. 1998-111; Dillon v. Commissioner, T.C.             
          Memo. 1998-5.                                                               
               Christopher testified that he and petitioner owe $96,000 to            
          the IRS for their 1981 through 1986 tax years.7  In her “Appeals            
          Transmittal and Case Memo”, Ms. Flandez listed the tax owed for             
          1982 through 1986 as $20,300.  According to an IRS transcript, as           
          of August 26, 1998, petitioner and Christopher owed $20,300 in              
          tax and approximately $61,000 in interest for their 1982 through            
          1986 tax years.                                                             
               The Form 433-A, Collection Information Statement for Wage              
          Earners and Self-Employed Individuals, that petitioner and                  
          Christopher signed on February 28, 2003, contained the following            
          statements:  Petitioner and Christopher owned their home; they              
          had no dependents they could claim on their tax return; they had            
          a Bank of America checking account with a balance of $4,000;                

               7  We note that the 1981 tax year is not in issue.  See                
          supra note 2.                                                               
               Additionally, on brief petitioner makes claims regarding the           
          total liability relating to the Hoyt investment for 1981 through            
          1996.  Petitioner’s tax years 1987 through 1996 also are not                
          before the Court.  Even if they were, according to petitioner’s             
          own estimate of the total tax liability, petitioner and her                 
          husband have substantial assets (real property and investments)             
          and credit that could be used to pay the total tax liability for            
          1981 through 1996 without creating economic hardship.                       





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