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$5,193.31 in medical expenses; and a self-prepared chart listing
$6,018.70 in medical expenses that are not covered by their
insurance and $1,014.35 under “Flex Plan” for 2002.
Petitioner testified that her oldest daughter, Tina, suffers
from health problems, is totally disabled, and that the financial
burden for her daughter rests on her and Christopher. Tina has
her own home, does not live with petitioner and her husband, and
petitioner and Christopher admitted that they cannot claim her as
a dependent. We also note that on the Form 433-A, petitioner and
Christopher stated that they had no dependents they could claim
on their tax return.
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.
Additionally, petitioner and her husband have substantial
assets (real property and investments) and credit that could be
used to pay a tax liability as high as $96,000 without creating
economic hardship. We conclude that petitioner will not
experience economic hardship if relief from the liabilities is
not granted given her current level of income and assets. See
Alt v. Commissioner, 119 T.C. at 314-315; Von Kalinowski v.
Commissioner, supra; Walters v. Commissioner, supra; Dillon v.
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