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attributable to Mr. Keitz since Mrs. Keitz's taxes on her wages
had been paid through withholding.
Given these facts, the Court concludes that petitioner at
the time she signed the return did not know or have reason to
know that the tax due would not be paid. The Court rejects
respondent's argument that she possessed such knowledge or failed
to fulfill a duty of inquiry. The Court concludes that
petitioner has satisfied this element.
3. Petitioner Will Suffer Economic Hardship
Respondent contends that petitioner failed to show that she
would suffer economic hardship if relief were denied. In
determining whether a requesting spouse will suffer economic
hardship if the relief is not granted, Rev. Proc. 2000-15, supra,
looks to section 301.6343-1(b)(4), Proced. & Admin. Regs., for
guidance. Rev. Proc. 2000-15, sec. 4.02(1)(c). Economic
hardship is present if satisfaction of the tax liability in whole
or in part will cause the taxpayer to be unable to pay her
reasonable basic living expenses. Sec. 301.6343-1(b)(4), Proced.
& Admin. Regs.
In 2000, petitioner earned $25,689 and received
approximately $1,600 per month from Mr. Keitz for alimony and
child support for three minor children. Petitioner had monthly
expenses of $2,821, after which she had $920 per month remaining.
Petitioner did not present any other evidence regarding any
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