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We conclude that satisfaction of the tax liabilities in
issue will not cause petitioner to be unable to pay reasonable
basic living expenses. Although petitioner may not be currently
employed, she states in her brief that she is considering a
return to the workforce to resume her teaching career.7
Petitioner is well educated, and she has posited no reason why
she could not be expected to earn income comparable to her 1999
salary of $48,572. Also, petitioner’s reasonable basic living
expenses are significantly less than the $3,775 listed on
petitioner’s Form 886-A. In the absence of more detailed
itemization, we do not consider her monthly expenses of $200 for
entertainment, $500 for charity, and $500 for gifts and travel to
be basic living expenses. Furthermore, petitioner’s mortgage
payments have presumably been reduced since petitioner paid off
the second mortgage on her home.
Even if petitioner were to be unable to resume her
employment, we believe that petitioner could liquidate a portion
of the IRA inherited from Mr. George in order to pay her tax
liabilities without causing her to be unable to pay reasonable
basic living expenses. The IRA provides petitioner with a
payment source independent of her compensation and retirement
pension.
7Petitioner’s brief states that she is 55 years old.
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