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economic hardship. Even if this were true, the evidence supports
respondent’s conclusion that petitioner will not suffer economic
hardship if section 6015 relief is not granted.
First, contrary to petitioner’s assertion on brief that she
may have a limited number of years left to work due to her
health, petitioner testified even though she had a heart attack a
few years ago that as of the time of trial she was in good
health. Second, even if we included petitioner’s tax liabilities
for years not in issue to reach a total tax liability estimated
by petitioner to be $155,000, petitioner has sufficient financial
ability to pay this amount.
As of February 2003, based on the information she provided,
the assets listed on the Form 433-A had a total current fair
market value of approximately $260,000.13 Additionally, after
allowing petitioner expenses of $5,56414 listed on the Form 433-
13 In reaching this figure, we used the following figures:
$4,398 for the checking and savings account, $166,235 for the
Form 433-A investments (the actual value of the 401(k)s
($54,924.97 plus $28,880.89 plus $73,355.46), the IRA
($4,183.39), the Personal M.M.P. account ($4,890.64)), $3,554 for
the cash value of the life insurance, $12,790 for the cars,
$9,160 for the other vehicles, and $64,037 for the equity in
their home (based on a fair market value of $187,500 (the
$150,000 listed 80 percent value adjusted to 100 percent--i.e.,
$150,000 divided by 80 percent) minus the outstanding debt of
$123,463). This figure does not include the $15,000 of credit
petitioner listed as available on the Form 433-A.
14 The Form 433-A states that transportation expense
includes lease payments. Petitioner and Mr. Ellison listed under
“other secured debt” the lease payment for their 2002 Ford
(continued...)
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