Mary A. George - Page 14

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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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