- 26 - A--a figure merely provided on the Form 433-A and not substantiated by any underlying evidence--petitioner had $1,134 per month (approximately $13,600 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. Accordingly, we conclude that respondent was correct, and did not abuse his discretion, in determining that petitioner would not suffer economic hardship. Although not a specific factor listed in the revenue procedure, in considering all the facts and circumstances it is worth noting that petitioner was skeptical about the supposed tax benefits provided by the Hoyt partnerships and did not think it would work. Petitioner also argues that respondent made blanket “pro forma” denials of Hoyt investor section 6015 claims. We disagree. Respondent’s agents assigned to review petitioner’s claim conducted a full, impartial, and fair evaluation of petitioner’s section 6015 claim. They reached their conclusions 14(...continued) Ranger. Petitioner did not provide evidence regarding how the amount of the transportation expense on the Form 433-A was calculated. Accordingly, in determining the amount of monthly expenses, petitioner may have double counted the lease payment for the 2002 Ford Ranger.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011